TPO couldn’t make independent evaluation of STPs of assessee to fix ALP of software services rendere

IT/ILT : Where in transfer pricing proceedings, TPO made addition to assessee's ALP in respect of software development services rendered to AE by benchmarking each STP unit of assessee on stand alone basis, in view of fact that profit of each of STP units of assessee company could not be evaluated independently of one another, they could not be segregated and therefore, impugned addition deserved to be deleted