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PRINCIPAL COMMISSIONER OF INCOME-TAX-01 Versus ACTIS GLOBAL SERVICES PVT. LTD

2016 (8) TMI 1197 - DELHI HIGH COURT

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 Info .....

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e capital and financial services markets, ESL works in the area of sales, marketing and supporting financial services. The financial profile of the two KPOs could not be said to be similar from the point of view of the type of businesses they were ca .....

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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 comparab .....

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( KPO‟) entity, and therefore, on the face of it the exclusion of Infosys BPO from the list of comparables does not call for interference. 4. As far as the exclusion of ESL is concerned, the ITAT appears to have relied upon para 31 of the decis .....

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iew 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 de .....

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trum 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 functionall .....

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f the aforesaid factors would have a material bearing on the profitability of the two entities. Treating the said entities to be comparables only for the reason that they use Information Technology for the delivery of their services, would, in our op .....

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