ITAT Pune Excludes Cybercom Datamatics as Comparable, Upholds InfoBeans in TP Case

Nethawk Networks India Private Limited Vs ACIT (ITAT Pune) The Pune ITAT partly allowed the assessee’s appeal against the final assessment order passed under Sections 143(3) read with 144C(13) of the Income-tax Act for AY 2012-13. The sole dispute concerned a transfer pricing adjustment of Rs.1,35,74,804 relating to the international transaction of providing software development services to the assessee’s Associated Enterprise (AE). The assessee had applied the Transactional Net Margin Method (TNMM) with Operating Profit/Operating Cost (OP/OC) as the Profit Level Indicator (PLI). W...