2016 (8) TMI 1197

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....evenue against the impugned order dated 10th December, 2015 passed by the Income Tax Appellate Tribunal („ITAT‟) in ITA No. 30/Del/2015. 2. The two questions urged by the Revenue are: (i) whether the ITAT has erred in excluding Infosys BPO from the final list of comparables, and  (ii) whether the ITAT erred in excluding M/s Eclerx Services Ltd. (ESL) from the ....

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....th similar uncontrolled transactions/entities. ITeS encompasses a wide spectrum of services that use Information Technology based delivery. Such services could include rendering highly technical services by qualified technical personnel, ITA 102/2015 Page 31 of 42 involving advanced skills and knowledge, such as engineering, design and support. While, on the other end of the spectrum ITeS would al....

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....ed counsel for the Revenue, that the ITAT ought not to have excluded ESL as a comparable because both ESL and the assessee were KPOs and both were catering to high-end clients. 6. The above submission overlooks what ITAT itself has noted in its impugned order, that the function profile of the two companies were different. While the Assessee is catering to the capital and financial services mark....