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2016 (8) TMI 1197 - DELHI HIGH COURT

2016 (8) TMI 1197 - DELHI HIGH COURT - TMI - TPA - selection of comparable - Held that:- As far as the exclusion of Infosys BPO is concerned, it is an admitted position that the Assessee is a Knowledge Processing Outsourcing ("KPO") entity, and therefore, on the face of it the exclusion of Infosys BPO from the list of comparables does not call for interference. - As far as the exclusion of ESL ITAT itself has noted in its impugned order, that the function profile of the two companies were di .....

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preferred by the Revenue against the impugned order dated 10th December, 2015 passed by the Income Tax Appellate Tribunal ( ITAT‟) in ITA No. 30/Del/2015. 2. The two questions urged by the Revenue are: (i) whether the ITAT has erred in excluding Infosys BPO from the final list of comparables, and (ii) whether the ITAT erred in excluding M/s Eclerx Services Ltd. (ESL) from the list of comparables? 3. As far as the exclusion of Infosys BPO is concerned, it is an admitted position that the As .....

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31......We find it difficult to accept this view as it is contrary to the fundamental rationale of determining ALP by comparing controlled transactions/entities with similar uncontrolled transactions/entities. ITeS encompasses a wide spectrum of services that use Information Technology based delivery. Such services could include rendering highly technical services by qualified technical personnel, ITA 102/2015 Page 31 of 42 involving advanced skills and knowledge, such as engineering, design and .....

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