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 Marketin

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