ITAT Directs Fresh TP Study for Non-US AEs After MAP Resolution

NI Systems (India) Pvt. Ltd. Vs DCIT (ITAT Bangalore) Income Tax Appellate Tribunal (ITAT) Bangalore has remanded the case of NI Systems (India) Pvt. Ltd. for a fresh transfer pricing (TP) study. The dispute arose over the applica-bility of the arm’s length price (ALP) determined in Mutual Agreement Procedure (MAP) proceedings for US-based Associated Enterprises (AEs) to the company’s non-US AEs. The assessee, a subsidiary of a US-based entity engaged in software and hardware development, had challenged the selection of com-parables for benchmarking its international transactions. Whil...