The Income Tax Appellate Tribunal excluded Infosys BPO and Eclerx Services Ltd. as comparables. The Delhi High Court rejected the Revenue's appeal, holding that the ITAT's view was plausible regarding the differing function profiles and business types.
The appeal filed by the Revenue is dismissed.
This page shows the compact analysis of this judgement. The full analysis — procedural history, issue-by-issue holdings with ratio and obiter, advocates, and paragraph-level evidence for every claim — is being added to the record in batches and will appear here when this judgement has been through it.
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PRINCIPAL COMMISSIONER OF INCOME-TAX-O1 ..... Appellant Through: Mr. Sanjay Kumar, Advocate.
versus
ACTIS GLOBAL SERVICES PVT. LTD . .... Respondent Through
CORAM: JUSTICE S. MURALIDHAR JUSTICE NAJMI WAZIRI
O R D E R % 05.08.2016
ITA 417/2016
Page 1 of 3
ITA 417/2016
Page 2 of 3
impugned order, that the function profile of the two companies were different. While the Assessee is catering to the 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 catering to.
S.MURALIDHAR, J
NAJMI WAZIRI, J
AUGUST 05, 2016 /kk
ITA 417/2016
Page 3 of 3
2 issues framed by the court
whether the Income Tax Appellate Tribunal erred in excluding Infosys BPO from the final list of comparables
whether ITAT erred in excluding M/s Eclerx Services Ltd. from the list of comparables for Arm's Length Price determination
Colour shows how this judgement treated each authority
Rampgreen Solutions Pvt Ltd v. Commissioner of Income TaxRelied on¶14
Rampgreen Solutions Pvt Ltd v. Commissioner of Income Tax (2015) 377 ITR 533 (Del)
Principal Commissioner of Income-Tax
Actis Global Services Pvt. Ltd.
S. MURALIDHAR
NAJMI WAZIRI
As recorded by the court registry
Judgements on the same questions, provisions and authorities, from every court
