https://www.taxtmi.com/caselaws?id=251099 The ITAT Hyderabad held that Infosys BPO Ltd. and Genesys International Ltd. are functionally dissimilar and must be excluded as comparables in transfer pricing analysis. Cosmic Global Ltd. was excluded due to outsourcing activities unrelated to the relevant segment, and Accentia Technologies Ltd. was excluded due to extraordinary profit impact from acquisitions. Allsec Technologies Ltd. was included as comparable despite a minor filter ratio difference. The claim related to contribution to the gratuity fund was allowed following SC precedent. The decision was against the Revenue, directing the AO to exclude or include companies based on functional analysis and relevant criteria rather than arbitrary thresholds. en-us Thu, 31 Jul 2014 00:00:00 +0530 Mon, 28 Jul 2025 15:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=251099 The ITAT Hyderabad held that Infosys BPO Ltd. and Genesys International Ltd. are functionally dissimilar and must be excluded as comparables in transfer pricing analysis. Cosmic Global Ltd. was excluded due to outsourcing activities unrelated to the relevant segment, and Accentia Technologies Ltd. was excluded due to extraordinary profit impact from acquisitions. Allsec Technologies Ltd. was included as comparable despite a minor filter ratio difference. The claim related to contribution to the gratuity fund was allowed following SC precedent. The decision was against the Revenue, directing the AO to exclude or include companies based on functional analysis and relevant criteria rather than arbitrary thresholds. Case-Laws Income Tax Thu, 31 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=251099