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| The Tax Publishers2019 TaxPub(DT) 5045 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
Giant size ITES provider like TCS E-Serve Ltd. having turnover several times more than that of assessee could not be compared with routine ITES/BPO service provider like assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Huge difference in turnover
Assessee rendered back office support services to its AE abroad. TPO considered TCS E-Serve Ltd. as comparable to assessee's case.Held: Giant size ITES provider like TCS E-Serve Ltd. having turnover several times more than that of assessee could not be compared with routine ITES/BPO service provider like assessee.
REFERRED : CIT v. Pentair Water India (P) Ltd. (2016) 381 ITR 216 (Bom) : 2015 TaxPub(DT) 5492 (Bom-HC).
FAVOUR : In assessee's favour.
A.Y. : 2011-12
INCOME TAX ACT, 1961
Section 92C
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