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| The Tax Publishers2020 TaxPub(DT) 3442 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
Acropetal Technologies Ltd. engaged in high-end services coming within the category of knowledge process outsourcing (KPO) could not be compared with a low-end BPO service provider like assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee rendered IT-enabled services (ITES) in the field of data processing to its AE abroad. TPO considered Acropetal Technologies Ltd. as comparable to assessee's case. Held: Acropetal Technologies Ltd. engaged in high-end services coming within the category of knowledge process outsourcing (KPO) could not be compared with a low end BPO service provider like assessee.
Relied:Rampgreen Solutions (P) Ltd. v. CIT 2015 TaxPub(DT) 3403 (Del-HC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2012-13 & 2013-14
INCOME TAX ACT, 1961
Section 92C
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