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| The Tax Publishers2020 TaxPub(DT) 2238 (Bang-Trib) : (2021) 186 ITD 0765 INCOME TAX ACT, 1961
Section 92C
M/s. E-Clerx Services Ltd. mainly engaged in providing high-end KPO services involving specialised knowledge and domain expertise in the field could not be compared with assessee engaged in providing low end services to AEs.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee rendered IT enabled services to AE abroad. TPO considered M/s. E-Clerx Services Ltd. as comparable to assessee's case.Held: M/s. E-Clerx Services Ltd. mainly engaged in providing high-end KPO services involging specialised knowledge and domain expertis in the field could not be compared with assessee engaged in providing low end services to group concerns.
Followed:Maersk Global Centres (India) Private Limited v. Asstt. CIT [ITA No. 7466/Mum/2012] : 2014 TaxPub(DT) 1484 (Mum-Trib).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 92C
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