https://www.taxtmi.com/caselaws?id=263014 The HC set aside the ITAT's confirmation of transfer pricing adjustments involving two comparables, e-Clerx Services Ltd. and Vishal Information Technologies Ltd., used to determine the ALP for services rendered by the assessee to its overseas AE. The court held that these entities were not functionally comparable with the assessee, as their services, business models, and cost structures materially differed. The HC emphasized that merely sharing the IT-enabled services label does not establish comparability, given the wide spectrum of ITeS activities. Consequently, the selection of these comparables was erroneous, and the transfer pricing adjustment was not justified. The decision was against the Revenue. en-us Mon, 10 Aug 2015 00:00:00 +0530 Fri, 25 Jul 2025 12:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=263014 The HC set aside the ITAT's confirmation of transfer pricing adjustments involving two comparables, e-Clerx Services Ltd. and Vishal Information Technologies Ltd., used to determine the ALP for services rendered by the assessee to its overseas AE. The court held that these entities were not functionally comparable with the assessee, as their services, business models, and cost structures materially differed. The HC emphasized that merely sharing the IT-enabled services label does not establish comparability, given the wide spectrum of ITeS activities. Consequently, the selection of these comparables was erroneous, and the transfer pricing adjustment was not justified. The decision was against the Revenue. Case-Laws Income Tax Mon, 10 Aug 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=263014