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| The Tax Publishers2020 TaxPub(DT) 2219 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Infosys Ltd. engaged in providing service in various areas of sourcing and procurement, customer services, finance and accounting legal process outsourcing and financial services, etc. was not comparable to routine back office services provider like assessee.
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Transfer pricing - Determiantion of ALp - Selection of comparables - Functional dissimilarity
Assessee rendered IT enabled services to AE abroad. TPO considered Infosys BPO Ltd. as comparable to assessee's case.Held: Infosys BPO was providing services in various areas of sourcing and procurement, customer services, finance and accounting legal process outsourcing, sales and fulfilment, analytics, business platforms, business transformation services, human resource outsourcing and technology solution optimisation. It also provided financial services and insurance, manufacturing, energy utilities communications and services and retail, consumer packaged foods, logistics and life services. Further in its annual report it had been mentioned that services provided were different from routine back office services. This noting itself mades this company not functionally similar with that of assessee. Hence, there could be no comparability analysis.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2014-15
INCOME TAX ACT, 1961
Section 92C
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