https://www.taxtmi.com/caselaws?id=397227 Transfer pricing adjustment was held unsustainable because the assessee's functions were back office support services and could not be re-characterised as KPO when its earlier-year profile had already been accepted. Comparables with materially different business models or KPO profiles, including Eclerx Services Ltd., Vishal Information Technologies Ltd., Crossdomain Solutions and Datamatics Financial Services, were found functionally incomparable; Datamatics Financial Services also failed the export filter. The rejection of Allsec Technologies, R Systems International Ltd. and CG Vak Software & Exports Ltd. was not supported by specific reasons, particularly where they had been accepted in earlier years and were not shown to be persistent loss-makers. The adjustment was directed to be recomputed afresh by excluding dissimilar comparables and including wrongly rejected ones. en-us Thu, 23 Jul 2020 00:00:00 +0530 Mon, 10 Aug 2020 13:04:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=397227 Transfer pricing adjustment was held unsustainable because the assessee's functions were back office support services and could not be re-characterised as KPO when its earlier-year profile had already been accepted. Comparables with materially different business models or KPO profiles, including Eclerx Services Ltd., Vishal Information Technologies Ltd., Crossdomain Solutions and Datamatics Financial Services, were found functionally incomparable; Datamatics Financial Services also failed the export filter. The rejection of Allsec Technologies, R Systems International Ltd. and CG Vak Software & Exports Ltd. was not supported by specific reasons, particularly where they had been accepted in earlier years and were not shown to be persistent loss-makers. The adjustment was directed to be recomputed afresh by excluding dissimilar comparables and including wrongly rejected ones. Case-Laws Income Tax Thu, 23 Jul 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=397227