In the result, appeal filed by the assessee stands partly allowed
Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary
Transfer Pricing Officer (TPO) for the purpose of determination of ALP in respect of the above international transaction. 4 The TPO vide order dated 09/10/2023 passed u/s. 92CA(3), suggested the TP adjustment in respect of software development agreement of Rs. 12,84,50,000/- and also interest on delayed receivables of Rs. 5,97,26,729/- u/s. 92CA