ITAT Allows BAPA Margin for Non-US AE Transactions Due to Identical FAR Profile

Synchrony International Services Private Limited Vs ACIT (ITAT Hyderabad) The Hyderabad Bench of the Income Tax Appellate Tribunal (ITAT) allowed the appeals filed by the assessee for Assessment Years 2016-17, 2017-18, and 2018-19 concerning transfer pricing adjustments relating to Information Technology Enabled Services (ITeS) rendered to Associated Enterprises (AEs). For AY 2016-17, the assessee challenged the order of the Commissioner of Income Tax (Appeals) [CIT(A)] on the ground that the CIT(A) failed to adjudicate issues relating to international transactions with non-US based AEs that w...