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M/s. Lason India Pvt. Ltd. Versus Joint Commissioner of Income Tax, Company Range-II, Chennai

Transfer price adjustment - payment of subsidiaries - Pass through cost consideration for arriving at operative profit or operating profit margin of the assessee - Held that:- As it is an admitted fact that the assessee itself included the pass through cost in its Profit and Loss Account. It is not the case of assessee that it is charged only mark up receivable from A.E in its P&L A/c. It is also admitted fact that assessee raised bills upon its A.E as payment from its A.E and received the payme .....

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is justified in considering the pass through cost also for arriving at the operative cost/operating cost and the decision relied upon by the ld.A.R cited above have no application. - Decided against assessee. - Suitable adjustments to account for differences in the risk profile of the assessee and its comparables - Held that:- We direct the TPO to allow risk adjustment at 1% as decided in the case of M/s.HELLOSOFT INDIA (P.) LTD. Vs. DCIT. [2014 (4) TMI 72 - ITAT HYDERABAD ] - Carry for .....

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arida,Advocate For The Respondent : Mr.Milind Madhukar Bhusari, JCIT,DR ORDER PER CHANDRA POOJARI, ACCOUNTANT MEMBER This appeal of the assessee is directed against the assessment order passed u/s.143(3) read with section 144C(13) of the Act dated 25.02.2014 which in turn emanated from the direction of Dispute Resolution Panel,(DRP),Chennai dated 20.12.2013 pertaining to assessment year 2009-10. 2. The first ground raised by the assessee is that the TPO erred in rejecting the assessee s Transfer .....

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of the case are that the assessee is a wholly owned subsidiary of Lason System Inc. USA which is in turn held by Lason Inc., Michigan USA. The assessee is engaged in rendering data conversion services to its ultimate parent company Lason Inc., Michigan USA in the area of forms processing, E-publishing and support systems and software services. The assessee company had eITA filed its return of income declaring Nil income on 29.09.2009. The return of income was processed u/s.143(1) of the Act on .....

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. The case was referred to the TPO for computation of ALP as the assessee has made international transactions exceeding ₹ 15 crores. Thereafter the TPO passed an order u/s.92CA of the Act dated 31.12.2012, making an upward adjustment of ₹ 21,60,43,705/-. The Additional CIT, Company Range-II issued draft assessment order u/s.143(3) r.w.s.144C on 25.03.2013, incorporating the adjustment suggested by the TPO, besides making addition towards provision made for loss on derivative contract .....

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ubmitted that the assessee outsources the work to its Indian associate Vetri Software India Pvt. Ltd and to many other independent units that carry out the data entry work on a continuous basis. The entire outsourced work is classified under DATA CONVERSON CHARGES in the P&L A/c amounting to ₹ 29,84,16,215/- ,which also include the amount paid to its wholly owned subsidiary Vetri Software of ₹ 8,55,83,359/- during the A.Y 2009-10. This work is merely on outsourced job-work having .....

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rk up @ 7% on cost in respect of pass through cost also. The assessee has included pass through cost in its profit and loss account. Therefore, TPO rejected the contention of the assessee. 3.3 DRP observed that if the assessee has included pass through cost in its P&L A/c and charged markup on it also then this Panel finds that there is no scope for raising any objection against it by the assessee. Further, DRP s of the view that outsourced work by the assessee to it s subsidiary and other i .....

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ary and other independent units the bills have been raised by these entities on the Assessee and the Assessee has made the payment to them on its own account and not on behalf of the A.Es. Therefore, the payments to the subsidiary and other independent units by the Assessee cannot be categorized as pass through cost as it is not a payment from A.Es to the subsidiary of the Assessee and Assessee acting merely as a conduit. Hence, it is not a pass through cost and therefore TPO rightly included on .....

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he Tribunal in the case of DCIT Vs. M/s.Cheil Communications India (P) Ltd., reported in [2011] 137 TTJ 539 (Delhi Tribunal) wherein held that:- 40. The rival contentions of both the parties have been considered and orders of the authorities below have carefully been perused. The only question that falls for our consideration is with regard to the method of computing profit/TC margin whether on gross basis as done by the TPO or net basis as worked out by the assessee. In this case the assessee h .....

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of operative profit on the total cost on the basis of net revenue by way of mark-up received from the associate concern. The payment made by the assessee to third party vendor/media agencies for and on behalf of the principal has not been included in the total cost for determining the profit margin, though, on the other hand, the TPO has included the payment reimbursed by the assessee's associate enterprise to the assessee on account of payment made to third party vendor/media agencies. It .....

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ots to its customers or associate concern. For performing the functions for and on behalf of AEs, the assessee is remunerated by its AEs on the basis of a fixed commission/charges based on expenses or cost incurred by the assessee for release of a particular advertisement. It is also to be noted that advertising space (be it media, print or outdoor), has been let out by third party vendors in the name of ultimate customers and beneficiary of advertisement. We have gone through the invoices and p .....

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ement agency, the bad debt risk is borne by the third party vendor and not by the advertising agency i.e. the assessee. It is, thus, clear that the assessee has not assumed any risk on account of non-payment by its customers or AEs. At this stage a useful reference may be made to ITS 2009 Transfer Pricing Guidelines accepted by the OECD where it is laid down that when an AE is acting only as an agent or intermediary in the provision of service, it is important in applying the cost plus method th .....

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pe of case, it will be appropriate to pass on the cost of rendering advertising space, to the credit recipient without a mark-up and to apply a mark-up only to the costs incurred by the intermediary in performing its agency function. These guidelines are as under : "3.41 In applying the transactional net margin method, various considerations should influence the choice of margin used for example, these considerations would include how well the value of assets employed in the calculations is .....

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return or mark-up is appropriate for the performance of an agency function rather than for the performance of the services themselves. In such a case, it may not be appropriate to determine arm's length pricing as a markup on the cost of the services but rather on the costs of the agency function itself or alternatively, depending on the type of comparable data being used, the mark-up on the cost of services should be lower than would be appropriate for the performance of the services themse .....

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gh cost in its Profit and Loss Account. It is not the case of assessee that it is charged only mark up receivable from A.E in its P&L A/c. It is also admitted fact that assessee raised bills upon its A.E as payment from its A.E and received the payments from its A.Es. It is also brought on record that for the work got done by the assessee from its subsidiary and other independent units, the bills have been raised by these entities on the assessee and the assessee has made the payments to the .....

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in this appeal is that the TPO/DRP grossly erred in choosing comparables (i) Cosmic Global, ii) E4e Health care Business Services Ltd., iii) Accentia iv)Microgenetics and v) Allsec Technologies Ltd.), which are functionally different or having occurrence of extra-ordinary events. 4.1.1 Regarding Cosmic Global Ltd., , ld.A.R submitted that this company is engaged in translation, audit and medical transcription business. As against it, the assessee is engaged in data processing service. The asses .....

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as compared to the assessee. Further, he relied on the judgment of Delhi High Court in the case of Rampgreen Solutions Pvt Ltd. Vs. CIT in ITA No.102 /2015 vide order dated 10.08.2015 specifically following:- 31. 1n the present case, the Tribunal noted that Vishal and eClerx were both engaged in rendering ITeS. Th Ttiluna1 held that, once a service falls under the category of ITeS, then there is subclassification of segment Thus, according to Tribunal, no differentiation could be made between t .....

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While, on the other end of the spectrum ITeS would also include voice-based call centers that render routine customer support for their clients. Clearly, characteristics of the service rendered would be dissimilar. Further, both service providers cannot be considered to be functionally similar. Their business environment would he entirely different, the demand and supply for the services would he different, the assets and capital employed would differ, the competence required to operate the two .....

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s, however, a contrary view had been taken by several benches of the Tribunal in other cases. In Capital IQ Information System India (F,) Ltd. v. Dy. CIT, (IT) [2013] 32 taxmann.com 21 and Lloyds TSB Global Services Pvt. Ltd. v. DCIT, (ITA No. 5928/Mum/2012 dated 2lth November 2012), the Hyderabad and Mumbai Bench of the Tribunal respectively accepted the view that a BPO service provider could not be compared with a KPO service provider. 33. The Special Bench of the Tribunal in Maersk Global Cen .....

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ts ability to move up the value chain through KPO service offering. For the aforesaid reasons, the Special Bench of the Tribunal held that ITeS Services could not he bifurcated as BPO and KPO Services for the purpose of comparability analysis in the first instance. The Tribunal proceeded to hold that a relatively equal degree of comparability can be achieved by selecting potential comparables on a broad functional analysis at ITeS level and that the comparables so selected could be put to furthe .....

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ed skills and knowledge for providing services. Thus, the expression KPO in common parlance is used to indicate an ITeS provider providin.g a completely different nature of service than any other BPO service provider. A KPO service provider would also be functionally different from other BPO service providers, inasmuch as the responsibilities undertaken the activities performed, the quality of resources employed would be materially different. In the circumstances, we are unable to agree that bro .....

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e. Thus, where the tested party is not a KPO service provider, an entity rendering KPO services cannot be considered as a comparable for the purposes of Transfer Pricing analysis. The perception that a BPO service provider may have the ability to move up the value chain by offering KPO services cannot he a ground for assessing the transactions relating to services rendered by the BPO service provider by benchmarking it with the transactions of KPO services providers. The object is to ascertain t .....

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cases where the categorization of services rendered cannot be defined with certainty, it would be apposite to employ the broad functionality test and then exclude uncontrolled entities, which are found to be materially dissimilar in aspects and features that have a bearing on the profitability of those entities. However, where the controlled transactions are clearly in the nature of lower-end ITeS such as Call Centers etc. for rendering data processing not involving domain knowledge, inclusion o .....

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sed, risks assumed. This is essential to ensure the efficacy of the exercise. There is sufficient flexibility available within the statutory framework to ensure a fair ALP. 37. Applying the aforesaid principles to the facts of the present case, it is once again clear that both Vishal and eClerx could not be taken as comparables for determining the ALP. Vishal and eClerx, both are into KPO Services. In Maersk Global Centers (India) Pvt. Ltd. (supra), the Special Bench of the Tribunal had noted th .....

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ther, the functions undertaken (i.e. the activities performed are also not comparable with the Assessee. In our view, the Tribunal erred in holding that the functions performed by the Assessee were broadly similar to that of eClerx or Vishal. The operating margin of eClerx, thus, could not be included to arrive at an ALP of controlled transactions, which were materially different in its content and value. In Maersk Global Centers (India) Pvt. Ltd. (supra), the Special Bench of the Tribunal had n .....

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ld.D.R made his submission that neither receipts nor expenditure have influenced the financials of Cosmic Global Ltd. ld.D.R further pointed out that the difference between the assessee and Cosmos Global Ltd do not vitiate the comparability and hence no interference is called for.. 4.1.3 We have heard both the parties and perused the material on record. M/s.Cosmic Global Ltd. is mainly engaged in ITES and it qualified as a comparable to assessee s case. As observed by DRP, neither receipts nor .....

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4.2 Regarding E4e-Healthcare Business Services Ltd. , the ld.A.R submitted that M/s.E4e-Healthcare Business Services Ltd., is in providing end to end healthcare services which are higher value added services requiring high skilled employees as against simple data entry service provided by the assessee. The ld.A.R has also submitted that E4e-Healthcare Business Services Ltd., has not incurred any employee expenditure cost. Further, the ld.A.R submitted that E4e-Healthcare Business Services Ltd., .....

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by the assessee. However, the assessee has not placed any details of the employees regarding their qualification or skill. Further, the acquisition of M/s.Nittancy Outsourcing Ltd. by M/s. E4e-Healthcare Business Services Ltd., in the year of 2006, which is no relevance to the assessment year 2009-10. Being so, the M/s. E4e-Healthcare Business Services Ltd., and the assessee being in similar business, we do not find any reason to E4e- Healthcare Business Services Ltd. to exclude as comparable. .....

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ent year 2009-10 also, the company has acquired M/s.Oak Technologies Inc. ld.A.R submitted that similar to other comparables the skill-set required by the assessee company. 4.3.2 On the other hand, ld.D.R relied on the order of DRP. 4.3.3 We have heard both the parties and perused the material on record. As seen from the records, M/s.Accentia Technologies Ltd., acquired various companies from year by year. More so, in the assessment year under consideration i.e. 2009-10, the assessee has acquire .....

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. Accordingly, this ground of assessee is allowed and M/s.Accentia Technologies Ltd., is to be excluded from comparables. 4.5 Regarding M/s.Micro Genetics Services Ltd., the ld.A.R submitted that M/s.Micro Genetics Services Ltd., is into providing Medical Transcription Services which are much higher in the value added service chain as against simple data entry service provided by the assessee. 4.5.1 On the other hand, ld.D.R relied on the order of DRP. 4.5.2 As discussed in the case of E4e-Healt .....

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t Management Services Division of i2i Telesource Pvt. Ltd., the ld.A.R submitted that the total value of acquisition is only 4.76 crores which is less than 5% of the total turnover of the company. ld.A.R submitted that it should not have been rejected as comparables. 4.6.1 On the other hand, ld.D.R submitted that the TPO had applied diminishing revenue /persistent losses including the F.Y 2008-09 are rejected as comparables. The TPO has excluded all those companies with persistent losses/diminis .....

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es and therefore, the DRP declines to give any direction to the TPO. 4.6.2 We have heard both the parties and perused the material on record. It is admitted fact that financials of M/s.Allsec Technologies Ltd., shows loss. This Tribunal consistently holding that loss making company cannot be considered as comparable with profit making companies. For this purpose, we place reliance on the Co-ordinate Bench of Hyderabad in the case of Capital IQ Information Systems (India) Pvt. Ltd., Vs. DCIT(Int. .....

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be considered as comparable. Hence, the ground of the assessee is rejected. 5.1 The next ground is with regard to not making suitable adjustments to account for differences in the risk profile of the assessee and its comparables. 5.2 According to ld.A.R, the TPO erred in ignoring the difference in risk profiles of the assessee and its comparable companies and in not providing any risk adjustment in this regard. He placed reliance in the case of M/s.HELLOSOFT INDIA (P.) LTD. Vs. DCIT reported in .....

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there is difference in the risk level and upholds the approach of the TPO. 5.4 We have heard both the parties and perused the material on record. Similar issue is considered by the Co-ordinate Bench of the Tribunal in the case of M/s.Hellosoft India (P.) Ltd. Vs. DCIT cited supra wherein held as follows:- 18. As regards 4th issue relating to risk filter, as submitted by the learned AR, this issue is also covered by the decision of the coordinate bench in assessee's own case for AY 2005-06 an .....

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) has held that no separate adjustment is required on account of risk and functional difference, the Incometax Appellate Tribunal Delhi Bench in the case of Sony India (P.) Ltd. v. Dy. CIT [2008] 114 ITD 448 has held that deduction on account of ownership of intangibles, risk factors can be allowed. In aforesaid view of the matter, we are inclined to accept the view favourable to the assessee. We therefore uphold the direction of the CIT (A) in this regard in allowing the benefit of risk adjustm .....

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the IT Act, thus restricting the depreciation claim of ₹ 2,63,35,680/- to the balance available profits of ₹ 33,33,422/-. The balance amount of depreciation of ₹ 2,30,02,258/- has been carried forward as current year loss. The ld.A.R submitted that the AO considered this improper and opined that the assessee has no depreciation loss. The ld.A.R submitted that the AO has to consider the Sec.10A benefits to be calculated per unit as per the provisions of the Act. Ld.A.R relied on .....

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