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Income Tax - Highlights / Catch Notes

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TP Adjustment - the Ld.TPO has observed that the services ...

Case Laws     Income Tax

January 15, 2024

TP Adjustment - the Ld.TPO has observed that the services rendered by the assessee are under two segments, but still holds the services of the assessee under SWD segment to be similar to that of the functions performed by the assessee under ITeS segment. We also note that the reasoning by the assessee Ld.TPO to aggregate both these segments are not justifiable and therefore cannot be upheld. - Matter restored back for reconsideration - AT

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