Transfer Pricing Adjustment Overturned: Assessee's $19/hr Rate Deemed Comparable to BPO Standard Using CUP Method.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....TP Adjustment - comparability adjustment on account of abnormal cost - There is no dispute on part of the revenue that in the BPO industry the prevalent rate for services was in the range of USD 8 to USD 15 per hour and was comparable/lower to the rate of USD 19 charged by the assessee from the AE and was at arm’s length applying CUP method. Thus, the adjustment made by the TPO is not sustainable even applying the CUP method. - AT....