https://www.taxtmi.com/caselaws?id=770592 ITAT Pune directed AO/TPO to exclude three comparables from transfer pricing analysis. Manipal Digital Systems Private Limited was excluded as its functions were not comparable to the assessee. CES Limited was excluded due to functional non-comparability, having mixed BPO/KPO functions, consistent with Vodafone Global Services precedent. MPS Limited was excluded due to extraordinary events of amalgamation and dissolution. The matter concerning Access Healthcare Services Private Limited was remanded to TPO for fresh adjudication, as the assessee's submissions regarding Revenue Cycle Management requiring specialized knowledge were not previously considered by TPO/DRP. en-us Mon, 24 Mar 2025 00:00:00 +0530 Wed, 14 May 2025 07:48:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770592 ITAT Pune directed AO/TPO to exclude three comparables from transfer pricing analysis. Manipal Digital Systems Private Limited was excluded as its functions were not comparable to the assessee. CES Limited was excluded due to functional non-comparability, having mixed BPO/KPO functions, consistent with Vodafone Global Services precedent. MPS Limited was excluded due to extraordinary events of amalgamation and dissolution. The matter concerning Access Healthcare Services Private Limited was remanded to TPO for fresh adjudication, as the assessee's submissions regarding Revenue Cycle Management requiring specialized knowledge were not previously considered by TPO/DRP. Case-Laws Income Tax Mon, 24 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770592