https://www.taxtmi.com/caselaws?id=773793 ITAT Hyderabad upheld TPO's recharacterization of assessee's engineering design services as KPO rather than BPO, finding the technical work involving 3D modeling, drawings, and analysis required highly skilled professionals. The tribunal upheld inclusion of Mahindra Consulting Engineers Ltd as comparable, rejecting arguments about business duration differences. However, it excluded Genesys International Corporation Ltd and L&T Technologies Services Ltd as non-comparable. The tribunal treated consultancy charges as operating costs but excluded goodwill amortization. Capacity utilization adjustment was rejected due to lack of evidence. The assessee's appeal was partly allowed. en-us Fri, 16 May 2025 00:00:00 +0530 Sat, 28 Jun 2025 08:31:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773793 ITAT Hyderabad upheld TPO's recharacterization of assessee's engineering design services as KPO rather than BPO, finding the technical work involving 3D modeling, drawings, and analysis required highly skilled professionals. The tribunal upheld inclusion of Mahindra Consulting Engineers Ltd as comparable, rejecting arguments about business duration differences. However, it excluded Genesys International Corporation Ltd and L&T Technologies Services Ltd as non-comparable. The tribunal treated consultancy charges as operating costs but excluded goodwill amortization. Capacity utilization adjustment was rejected due to lack of evidence. The assessee's appeal was partly allowed. Case-Laws Income Tax Fri, 16 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773793