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| The Tax Publishers2020 TaxPub(DT) 5466 (Kol-Trib) INCOME TAX ACT, 1961
Section 92C
Accentia Technologies Ltd. was a multi-location diversified Knowledge Process Outsourcing company, operating from multiple locations in India, USA, UK and the Middle East. It was engaged in SaaS (Software as a Service) model, services under Healthcare Receivables Cycle management including medical transcription, medical coding and billing and receivables management services. Accordingly, it could not be considered as functionally comparable to BPO service provider like assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee rendered back office processing/business process outsourcing services to its AE abroad. TPO considered Accentia Technologies Ltd. as comparable to assessee's case. Held: Accentia Technologies Ltd. was a multi-location diversified Knowledge Process Outsourcing company, operating from multiple locations in India, USA, UK and the Middle East. It was engaged in SaaS (Software as a Service) model, services under Healthcare Receivables Cycle management including medical transcription, medical coding and billing and receivables management services. Accordingly, it could not be considered as functionally comparable to BPO service provider like assessee.
REFERRED :
FAVOUR : In assesee's favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 92C
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