The Tax Publishers2020 TaxPub(DT) 3954 (Bang-Trib)

INCOME TAX ACT, 1961

Section 92C

Acropetal Technologies Ltd. engaged into high-end KPO services could not be compared with routine services provider like assessee.

Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity

Assessee rendered IT enabled back office support services to its AE abroad. TPO considered Acropetal Technologies Ltd.as comparable to assessee's case. Held: Acropetal Technologies Ltd. engaged into high-end KPO services could not be compared with routine services provider like assessee.

Followed:Aspect Technology Centre (India) (P) Ltd. v. ITO (ITA No. 187/Bang/2016 Order, dated 30-7-2020)

REFERRED :

FAVOUR : In assessee's favour

A.Y. : 2011-12

INCOME TAX ACT, 1961

Section 92C

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