ITAT Partly Allows TP Appeal by Excluding Cybercom as Software Comparable

Advertisement Velocity Tech-Sol India Pvt. Ltd. Vs ACIT (ITAT Pune) The Income Tax Appellate Tribunal (ITAT) adjudicated the assessee’s appeal against the final assessment order passed under Sections 143(3) read with 144C(13) of the Income-tax Act, 1961 for Assessment Year 2014-15. The assessee, a wholly owned subsidiary of its US parent company, was engaged in providing software development services on a cost-plus mark-up basis. It benchmarked its international transaction of software development and IT enabled services using the Transactional Net Margin Method (TNMM), adopting Opera...