2018 (1) TMI 1548

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.... ORDER The Revenue in its appeal under Section 260-A of the Income Tax Act, 1961 ('the Act') is aggrieved by the decision of the ITAT, which interfered with the Appellate Commissioner's decision. The Appellate Commissioner had set aside the Arms Length Price (ALP) decided by the Assessing Officer (AO), resulting in the adjustment to the extent of a profit margin of 29.05%. The Appellate Commis....

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....tself with the broader range of Information Technology (IT) enabled Back Office Support Services. In the other two cases of M/s Infosys BPO and Wipro BPO Ltd., the ITAT again, in the opinion of this Court, quite correctly held that the corporate entities had a significant brand presence for profits and large corporate size, which could not be compared to the assessee's transactions. As far as HCL ....