https://www.taxtmi.com/caselaws?id=431340 Functionally dissimilar high-end service providers with brand, scale and supernormal profit advantages were treated as unsuitable transfer pricing comparables, so Eclerx Services Ltd. and Infosys BPO Ltd. were excluded. The request to include ACE BPO Services Pvt. Ltd. and Datamatics Financial Services Ltd. required fresh examination because the record did not conclusively establish comparability or filter satisfaction, and the issue was remitted for verification. Disallowance of management fee and trade mark licence fee was also sent back for fresh factual scrutiny in line with earlier years. Depreciation at the higher rate on software licence fee was allowed on the basis of consistent treatment in the assessee's own earlier years. en-us Thu, 22 Sep 2022 00:00:00 +0530 Sat, 10 Dec 2022 10:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431340 Functionally dissimilar high-end service providers with brand, scale and supernormal profit advantages were treated as unsuitable transfer pricing comparables, so Eclerx Services Ltd. and Infosys BPO Ltd. were excluded. The request to include ACE BPO Services Pvt. Ltd. and Datamatics Financial Services Ltd. required fresh examination because the record did not conclusively establish comparability or filter satisfaction, and the issue was remitted for verification. Disallowance of management fee and trade mark licence fee was also sent back for fresh factual scrutiny in line with earlier years. Depreciation at the higher rate on software licence fee was allowed on the basis of consistent treatment in the assessee's own earlier years. Case-Laws Income Tax Thu, 22 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431340