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4.7. Details of the updated margin of the comparables along with the line by line margin calculation of comparables and the tested party. This should be reconciled with the audited accounts.

Please note that if the above information/ documents are not furnished by 18.12.2020, along with contemporaneous documentary evidence, the arm's length pricing for these intragroup services would be treated as Nil by applying CUP method."

2.4 In response, the assessee submitted its reply vide letter dated 13.01.2021, wherein it submitted that during AY 2017-18, the assessee had received allocation of expenses, incurred by its associated enterprise ('AE'), namely Compass Group Holding Plc on behalf of its affiliates and such expenses were incurred towards information technology ('IT') software licenses and support services (referred to as 'IT software licenses') which had been rendered by third party service providers to Compass Group affiliates, under an arrangement between the AE and such third party. The assessee also submitted the details of 'allocation for IT software licenses', 'benefits of receiving the IT software licenses', 'better IT platforms' and about 'cost benefit'. Further, the assessee also submitted legal arguments submitting that benefit test is not a method prescribed under the realm of the Act and placed various judicial ITA No.-511/Del/2022 and 1383/Del/2022 Compass India Support Services Pvt. Ltd.

7. The Ld. AR reiterated its submission before the AO/ Ld. DRP and filed a short synopsis and the relevant extract of the same is reproduced as under:

" In the case of: Compass India Support Services Private Limited Short Synopsis In reference to the ma er heard by the Hon'ble Bench on November 11, 2025, the Appellant respec ully submits a brief synopsis as directed -

1. The Appellant is a wholly owned subsidiary of Compass Group Netherlands B. V. (during AY 2017-18, it was a wholly owned subsidiary of Compass Group (Singapore) Pte Ltd) and ul mately owned by Compass Group PLC (Compass UK'). It is primarily engaged in providing integrated facility management ('FM") and catering services in India.

ITA No.-511/Del/2022 and 1383/Del/2022 Compass India Support Services Pvt. Ltd.

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4. It is submi ed that during the cap oned AY, in order for smooth business func ons and rendering services to its customers, the Appellant received alloca on of cost pertaining to so ware licenses from its AEs for INR. 59,30,009. Such expenses were incurred towards IT so ware licenses and support services (referred to as 'IT so ware licenses') which have been rendered by third party service providers to Compass Group affiliates, under an arrangement between the AE and such third party i.e. Microso .

c) Break-up of "Azure charges" as appearing in Inter-Company invoice for USD 8,135 which was further split in the ra o 50:50 for two Indian en es i.e. the Appellant and Compass Group India Support Services P. Ltd.

4 Microso CRM license: Break-up of Microso CRM license cost for 125-159 USD 5,188 allocated to Appellant alongwith the agreed rates.

ITA No.-511/Del/2022 and 1383/Del/2022 Compass India Support Services Pvt. Ltd.