ACIT vs ITC Infotech India Ltd.

Whether foreign Associated Enterprises (AEs) can be considered as the tested party for establishing arm's length price under transfer pricing provisions --- Held Yes; Whether the Cost Plus Method (CPM) is the most appropriate method for establishing arm's length price for services rendered by AEs --- Held Yes; Whether segmented accounts for AEs can be accepted for establishing arm's length price --- Held Yes; Whether software expenses are revenue expenditure or capital expenditure --- Held Revenue Expenditure; Whether education cess and higher education cess are allowable expenses under section 40(a)(ii) of the Income Tax Act --- Held Yes.