ITO vs Sabre Travel Technologies Pvt. Ltd.

Authority: ITAT Tribunal/Court: Bangalore Date: 2020-09-04 AY: 2011-12 Section: 144C(13), 92CA, 10A Acts: Income Tax Act 1961, Income-tax Rules 1962 Result: Partly Citation: 1220Taxpundit2411 Justices: N.V. VASUDEVAN VP & B R BASKARAN AM Appeal No: IT(TP)A Nos. 403/Bang/2016
Whether the Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP) erred in selecting comparable companies and computing working capital adjustment for determining Arm's Length Price (ALP) of international transactions involving Software Development Services --- Held: Partly in favor of assessee; Whether the Assessing Officer (AO) erred in disallowing lease rentals as revenue expenditure and in computation of deduction u/s 10A --- Held: In favor of assessee on deduction u/s 10A; lease rental issue remanded.

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