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| The Tax Publishers2020 TaxPub(DT) 3172 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
Eclerx Services Ltd. being a Knowledge Process Outsourcing (KPO) Service provider was not comparable to assessee engaged in IT enabled back office support services.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee rendered IT enabled back office support services to its AE abroad. TPO considered Eclerx Services Ltd. and Cross-domain Solutions as comparable to assessee's case. Held: Eclerx Services Ltd. being a Knowledge Process Outsourcing (KPO) Service provider, was not comparable to assessee engaged in back office support services.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2008-09
INCOME TAX ACT, 1961
Section 92C
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