https://www.taxtmi.com/caselaws?id=365120 HC held the assessee's activities are KPO, not BPO, because services required specialized, skill-based analysis; thus certain comparables were excluded as functionally dissimilar. Under amended s.92B, delay in realization of trading receivables attracts TP adjustment for notional interest, and charging interest on delayed receivables is a distinct international transaction requiring independent benchmarking. The ITAT's approach on interest and exclusion of the comparables was upheld in part, resulting in a decision partly for the assessee and partly for the revenue. en-us Thu, 09 Aug 2018 00:00:00 +0530 Tue, 14 Oct 2025 10:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=365120 HC held the assessee's activities are KPO, not BPO, because services required specialized, skill-based analysis; thus certain comparables were excluded as functionally dissimilar. Under amended s.92B, delay in realization of trading receivables attracts TP adjustment for notional interest, and charging interest on delayed receivables is a distinct international transaction requiring independent benchmarking. The ITAT's approach on interest and exclusion of the comparables was upheld in part, resulting in a decision partly for the assessee and partly for the revenue. Case-Laws Income Tax Thu, 09 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=365120