https://www.taxtmi.com/caselaws?id=281834 The ITAT Delhi ruled on transfer pricing adjustments for an assessee providing HR services, payroll processing, and data entry to its associated enterprise on a cost plus 10% basis. The tribunal deselected several comparables: TCS-e-Serve Ltd due to functional dissimilarity requiring skilled technical services; Infosys BPO Ltd for operating in niche areas unlike the assessee and having brand presence plus extraordinary acquisition events; and Excel Infoways Ltd for failing the TPO's own diminishing revenue filter while having super normal profits. However, R System International Limited was retained as comparable following HC precedent in McKinsey Knowledge Centre case, as audited quarterly results were provided with calculated margins for the relevant financial year. Regarding fixed asset purchases, the tribunal restored the matter to the Assessing Officer/TPO for recomputation following the tribunal's direction in the assessee's preceding assessment year case, allowing the grounds for statistical purposes. en-us Thu, 24 Aug 2017 00:00:00 +0530 Tue, 22 Jul 2025 12:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=281834 The ITAT Delhi ruled on transfer pricing adjustments for an assessee providing HR services, payroll processing, and data entry to its associated enterprise on a cost plus 10% basis. The tribunal deselected several comparables: TCS-e-Serve Ltd due to functional dissimilarity requiring skilled technical services; Infosys BPO Ltd for operating in niche areas unlike the assessee and having brand presence plus extraordinary acquisition events; and Excel Infoways Ltd for failing the TPO's own diminishing revenue filter while having super normal profits. However, R System International Limited was retained as comparable following HC precedent in McKinsey Knowledge Centre case, as audited quarterly results were provided with calculated margins for the relevant financial year. Regarding fixed asset purchases, the tribunal restored the matter to the Assessing Officer/TPO for recomputation following the tribunal's direction in the assessee's preceding assessment year case, allowing the grounds for statistical purposes. Case-Laws Income Tax Thu, 24 Aug 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=281834