Wednesday 29 April 2015

No additions by TPO due to differential man hour rate if services of assessee couldn't be bifurcated

IT/ILT : Where in respect of software development services rendered by assessee to its AE, TPO made certain addition relying upon difference in man hours rate charged by assessee from its AE and non-AEs, since price charged by assessee for rendering final composite work of software development services was aggregate price, it could not be bifurcated on basis of man hour rate and, therefore, impugned addition was to be set aside

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