ACCENTURE SERVICES P.LTD,MUMBAI vs. ADDL CIT RG 3(1), MUMBAI

In the result, assessee’s appeal is partly allowed

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

Transfer Pricing Officer has classified the income received under IPSA agreement to be of the nature of ITES and has also benchmarked it as such, the Assessing Officer cannot take a contrary view by stating that it is not in the nature of ITES only for disallowing assessee’s claim of deduction under section 10A of the Act. The Department