IT(TP)A No.210/Bang/2021 EIT Services India Pvt. Ltd., Bangalore Page 66 of 66 Accordingly, this issue is remitted to AO for fresh consideration in the light of above. 22. In the result, the appeal of the assessee is partly allowed for statistical purposes. Order pronounced in the open court on 22 nd Aug, 2022 Sd/- (Beena Pillai) Judicial Member Sd/- (Chandra Poojari) Accountant Member Bangalore, Dated 22 nd Aug, 2022. VG/SPS Copy to: 1. The Applicant 2. The Respondent 3. The CIT 4. The CIT(A) 5. The DR, ITAT, Bangalore. 6. Guard file By order Asst. Registrar, ITAT, Bangalore.