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ITAT upheld TPO's recharacterization of Appellant's engineering design services as Knowledge Process Outsourcing (KPO) rather than Business Process Outsourcing (BPO), finding the services involved highly technical work including 3D modelling, technical specifications, and structural analysis requiring specialized technical staff. Regarding comparable selection, ITAT upheld inclusion of Mahindra Consulting Engineers Ltd despite Appellant's RPT filter objections, but directed exclusion of Genesys International Corporation Ltd and L&T Technologies Services Ltd as functionally dissimilar. ITAT confirmed consultancy charges as operating costs but directed exclusion of goodwill amortization from operating expenses. Capacity utilization adjustment was rejected due to insufficient evidence. ITAT dismissed Appellant's challenge regarding inclusion of Code Ploy Engg. Ltd and E2G Engineering & Design Services Pvt Ltd as no grounds were raised before TPO/DRP. Appeal was partly allowed.
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