| The Tax Publishers2020 TaxPub(DT) 1287 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
Eclerx Services was engaged in data analytical, data processing services, pricing analytics, bundling optimization, content operation, sales and marketing support, product data management, revenue management. Furthermore, Eclerx Services also offered financial services such as real-time capital markets, middle and back-office support, portfolio risk management services and various critical data management services.The said diverse activities were not comparable with consultancy services rendered by the assessee. Moreover though some functions were similar, there were lot of other functions by M/s. Eclerx Services which were not done by the assessee. Hence, absence of segmental data made comparability not feasible.
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Transfer pricing - Determination of ALP - Selection of comparables - Diverse activities and lack of segmental data
Assessee rendered consultancy/information technology enabled services (ITeS) to AE abroad. TPO considered M/s Eclerx Services as comparable to assessee's case. Held: Eclerx Services was engaged in data analytical, data processing services, pricing analytics, bundling optimization, content operation, sales and marketing support, product data management, revenue management. Furthermore, Eclerx Services also offered financial services such as real-time capital markets, middle and back-office support, portfolio risk management services and various critical data management services.The said diverse activities were not comparable with consultancy services rendered by the assessee. Moreover though some functions were similar, there were lot of other functions by M/s. Eclerx Services which were not done by the assessee. Hence, absence of segmental data made comparability not feasible.
REFERRED :
FAVOUR : In assessee's favour
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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