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2015 (6) TMI 805 - AT - Income TaxTransfer Pricing adjustment - addition made to the value of international transaction entered into by the assessee with its associated enterprise in respect of Provision of Information Technology Enabled Service - selection of comparable - Held that:- Accentia Technologies Ltd. - As during the year under consideration there were extraordinary events that took place in the said concern which warranted exclusion of this company as a comparable. We therefore hold that the said concern cannot be considered as a comparable Coral Hub Ltd.(Earlier known as Vishal Information Technologies Ltd.) - The Tribunal in assessee’s own case for assessment year 2008-09 has given a finding that Coral Hub Ltd. could not be selected as a comparable.The said company was providing IT enabled services and was also engaged in other diversified activities. Further, it has outsourced its services to third party vendor and acted as intermediary between the final customer and the vendor. The assessee on the other hand was engaged in the running of a call centre and was providing technical support to its AEs. Cosmic Global Ltd. needs to be rejected on the ground that it was engaged in BPO and Translation services whereas assessee was an ITES provider, and therefore concern was functionally dissimilar. Crossdomain Solutions Ltd. was not comparable with the assessee as the said concern was engaged in the payroll activity apart from being engaged in KPO services. Also the said concern was identified as a Knowledge Process Outsourcing services provider (KPO) and not a simple business process outsourcing services provider, thus is to be excluded from the final set of comparables.
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