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| The Tax Publishers2020 TaxPub(DT) 4575 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
Accentia Technologies engaged in KPO services and also having faced extraordinary event of amalgamation during the year, could not be compared to BPO service provider like assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity and extraordinary event
Assessee rendered IT enabled services to AE abroad. TPO considered Accentia Technologies Ltd. as comparable to assessee's case.Held: Accentia Technologies Ltd. engaged in diversified services which included HRCM (using SaaS model was KPO and not BPO was functionally dissimilar to assessee. Also, there was extraordinary event of amalgamation during the year in case of Accentia Technologies Ltd. Hence, there could be no comparability analysis.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 92C
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