https://www.taxtmi.com/highlights?id=89899 ITAT upheld TPO's recharacterization of Appellant's engineering design services as Knowledge Process Outsourcing (KPO) rather than Business Process Outsourcing (BPO), finding the services involved highly technical work including 3D modelling, technical specifications, and structural analysis requiring specialized technical staff. Regarding comparable selection, ITAT upheld inclusion of Mahindra Consulting Engineers Ltd despite Appellant's RPT filter objections, but directed exclusion of Genesys International Corporation Ltd and L&T Technologies Services Ltd as functionally dissimilar. ITAT confirmed consultancy charges as operating costs but directed exclusion of goodwill amortization from operating expenses. Capacity utilization adjustment..... en-us Sat, 28 Jun 2025 08:32:06 +0530 Sat, 28 Jun 2025 08:32:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=89899 ITAT upheld TPO's recharacterization of Appellant's engineering design services as Knowledge Process Outsourcing (KPO) rather than Business Process Outsourcing (BPO), finding the services involved highly technical work including 3D modelling, technical specifications, and structural analysis requiring specialized technical staff. Regarding comparable selection, ITAT upheld inclusion of Mahindra Consulting Engineers Ltd despite Appellant's RPT filter objections, but directed exclusion of Genesys International Corporation Ltd and L&T Technologies Services Ltd as functionally dissimilar. ITAT confirmed consultancy charges as operating costs but directed exclusion of goodwill amortization from operating expenses. Capacity utilization adjustment..... Highlights Income Tax Sat, 28 Jun 2025 08:32:06 +0530 https://www.taxtmi.com/highlights?id=89899