TaxTMI 
TaxTMI 
2017 (8) TMI 1364
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...., Advocates ORDER C.M. No. 30036/2017 (for condonation of 7 days' delay in filing the reply) 1. The application has been filed by the Respondent seeking condonation of 7 days' delay in filing the reply. 2. For the reasons stated in the application, the delay in filing the reply is condoned. The application is allowed. ITA No. 924/2016 & C.M. No. 46656/2016 (for condonation of 430 days....
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....the Court is not inclined to condone the delay in filing the appeal. 6. Nevertheless, the appeal has also been examined on merits. 7. The short question urged by the Revenue in this appeal is whether the ITAT was correct in excluding Coral Hub Ltd.; M/s. Infosys BPO and M/s. Wipro BPO from the list of comparables for determining the arm's length price of the international transaction involvi....
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.... the total cost. When the business operations are out sourced, the profit margins are bound to increase substantially as compared to a business which is carried on through employees. Therefore, this company cannot be included in the list of comparables, though it might be carrying on the similar functions which assessee was carrying on. The functional profile no doubt is one of the major criteria ....
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....l was entirely different when compared to the Assessee who in that case was also carrying on a similar function and rendering knowledge process outsourcing service. It was observed by this Court that "plainly, a business model where services are rendered by employing one's own employees and using one's own infrastructure would have a different cost structure as compared to a business model....