TP adjustment deleted as recharacterization of business not warranted

Scientific Games India Private Limited Vs DCIT (ITAT Chennai) ITAT Chennai held that recharacterization of business from ‘software development service provider’ to ‘contract R&D service provider’ not justifiable as BAPA and TPO’s earlier assessment accepted characterisation of the Assessee to be a Software Development service provider. Hence, upward transfer pricing adjustment deleted. Facts- The Assessee is a Company was incorporated in the year 2005, as a wholly owned subsidiary of Bally Technologies Inc., USA. (currently known as LNW Gaming Inc.) The Assessee had entered into...