Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Tribunal upheld assessee's contention on functional dissimilarity of comparables E-clerx Services Ltd., Acropetal Technologies Ltd., Infosys BPO Ltd. and TCS EServe Ltd. based on factual consistency and Co-ordinate Bench ruling for earlier years. Directed exclusion of these comparables from list. Dismissed Revenue's Grounds of appeal. Rendered Cross Objection infructuous due to exclusion of comparables.
Tribunal upheld assessee's contention on functional dissimilarity of comparables E-clerx Services Ltd., Acropetal Technologies Ltd., Infosys BPO Ltd. and TCS EServe Ltd. based on factual consistency and Co-ordinate Bench ruling for earlier years. Directed exclusion of these comparables from list. Dismissed Revenue's Grounds of appeal. Rendered Cross Objection infructuous due to exclusion of comparables.
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