ITAT Bangalore directed AO to apply MAP rate on International Transactions

Conduent Business Services India LLP Vs ACIT (ITAT Bangalore) Conclusion: MAP rate should be applied by AO/TPO for the rest of the transitions of Rs.25,09,87,512 which was 4.42% of the total transactions. Accordingly, AO was directed to apply the MAP rate on the rest of the transactions for determination of the margin on the international transactions. Held: Assessee was engaged in 2 segments software development services , IT Enabled Services and Marketing Support Services during the impugned assessment year to US affiliate Companies and Non-US affiliate Companies. Assessee submitted that in ...