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2016 (7) TMI 1437 - AT - Income TaxTransfer pricing addition - comparable selection criteria - functional similarity - Held that:- Service provided by the assessee are in the nature of Information Technology Enabled Services (ITES) or commonly known as business process out sourcing (BPO) service relating to transaction processing, data entry, re–conciliation of statements and other similar support services. As per the terms of agreement, for the service provided by the assessee to its A.E., it is remunerated on a cost plus mark–up basis, thus companies functionally dissimilar with that of assessee need to be deselected from final list.
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