2020 (11) TMI 742 - ITAT DELHI - Income Tax

Head Note / Extract:
TP Adjustment - comparable selection - HELD THAT:- Functional profile of the assessee as described in the transfer pricing documentation, in respect of the ITES segment, shows that the assessee being a subsidiary of Steria UK Corporate Limited, a software service company in the United Kingdom (“UK”), provides IT enabled services (ITES) to the clients of its associated enterprises; that the marketing function including client acquisition is performed by the associated enterprise and the assessee performs ITES activity in relation to work outsourced /sub-contracted by the associated enterprise to the assessee; that it provides back office process outsourcing and inbound and outbound voice-based services; and that the delivery centers of the assessee are located in Noida, Chennai and Pune, from where Steria India delivers work on behalf of Seteria UK for Clients., companies functionally dissimilar with that of assessee need to be deselected. Volume of Related Party Transactions, Extra-ordinary year of operation and Functional profile of the assessee as spoken need to be taken care while selecting comparable.