Orange India TP Case: Segregation & Headcount Method Ordered

Orange Business Services India Solutions Private Ltd. Vs DCIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT) Delhi has set aside previous orders concerning the transfer pricing assessment of Orange Business Services India Solutions Private Ltd., remanding the matter back to the Transfer Pricing Officer (TPO) for fresh evaluation. The key directive from the Tribunal is to independently benchmark the taxpayer’s ‘Software Development’ (IT Services) and ‘IT Enabled Services’ (ITES) segments, departing from the earlier aggregated approach. The ITAT also stipulat...