https://www.taxtmi.com/caselaws?id=259427 Coral Hub was held not comparable for transfer pricing because, despite some functional similarity, its asset and risk profile materially differed and it incurred predominantly data entry charges (about 84.5% of expenditure), indicating low-end services; it was directed to be excluded. Eclerx was held functionally comparable since the assessee, though a captive service provider, rendered analytical, skill-intensive services rather than mechanical data processing; absence of extraordinary events in the relevant year led to rejection of the assessee's objection and retention of Eclerx. Infosys BPO and Wipro BPO were held not comparable due to huge turnover, economies of scale and brand intangibles vis-à-vis the assessee's small turnover; they were excluded. Working capital adjustment was held allowable in principle; the TPO was directed to grant it after verifying the quantum. en-us Fri, 27 Mar 2015 00:00:00 +0530 Wed, 31 Dec 2025 10:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259427 Coral Hub was held not comparable for transfer pricing because, despite some functional similarity, its asset and risk profile materially differed and it incurred predominantly data entry charges (about 84.5% of expenditure), indicating low-end services; it was directed to be excluded. Eclerx was held functionally comparable since the assessee, though a captive service provider, rendered analytical, skill-intensive services rather than mechanical data processing; absence of extraordinary events in the relevant year led to rejection of the assessee's objection and retention of Eclerx. Infosys BPO and Wipro BPO were held not comparable due to huge turnover, economies of scale and brand intangibles vis-à-vis the assessee's small turnover; they were excluded. Working capital adjustment was held allowable in principle; the TPO was directed to grant it after verifying the quantum. Case-Laws Income Tax Fri, 27 Mar 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259427