TaxTMI 
TaxTMI 
2023 (10) TMI 1132
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....direction of the Ld. Dispute Resolution Panel (DRP) vide direction dated 23/09/2014 for Asst. Year 2010-11. 2. We find that this appeal was originally disposed off by this Tribunal in ITA No.516/Del/ 2015 for AY 2010-11, dated 20/03/2018. Later the Miscellaneous Application was preferred by the assessee stating that ground No.3.5 seeking exclusion of Eclerx Services Limited from the set of comparable companies while determining Arm's Length Price (ALP), was not adjudicated by the Tribunal while passing the order dated 20/03/2018. Accordingly, this Tribunal vide its MA order in MA No.251/Del/2018 dated 09/09/2022 had recalled the order only for the limited purpose of adjudication of ground No.3.5 raised by the assessee in seeking exclusio....
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....y HSI and including it into Search Palace. Search Palace and the database of resumes are accessible by Heidrick & Struggles group's global operations. There are 2 categories of applications received in the mailboxes-solicited and unsolicited applications. The solicited applications are those for which Heidrick & Struggles group has a prospective employer and on whose request a search process has been initiated. In this case the applications are sought from candidates in respect of the particular vacancy. Both solicited and unsolicited applications are stored in the Search Palace database and reviewed by the executive search consultants for their specific projects. H&S KMC India is responsible for ensuring quality and c....
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....that have been open or on hold for more than 12 months to see if these searches should be cancelled/ terminated. This activity improves the quality of the data available through the Search Palace. 13 people are involved in this function. * Research Division The research organization is divided into the following functional areas, which include Executive Identification, and Business Development ("BD") Research. 64 people are involved in following activities: Executive Identification Based on the existing or future requirements of the AES, H&S KMC India Research team finds information about executives, various job profiles, compensation and benefit packages, relevant expertise required, specific technical s....
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.... of functional dis-similarity and relied upon order passed by ITAT, Delhi Bench in the case of Copal Research India Pvt. Ltd. (ITA No.1713/Del.2014) (available at pages 741 to 757 of the Paper Book-III). Assessee also raised objection that this company is a Knowledge Processing Outsourcing (KPO) company rather than routine service provider. 24 Comparability of ECLERX has been examined by the coordinate Bench in case of Copal Research India Pvt. Ltd. (supra) which is also engaged into ITES services similar to that of the assessee. 25. When we examine the functional profile of the assessee company which is into providing Information Technology (IT) Enables Back Office Support Services related to creation and maintenance of d....
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....the said company provides data analytics and data process solutions to some of the largest brands in the world and is recognized as experts in chosen markets-financial services and retail and manufacturing It is claimed to be providing complete business solutions by combining people, process improvement and automation It is claimed to have employed over 1500 domain specialists working for the clients. It is claimed that eClers is a different company with industry specialized services for meeting complex client needs, data analytics KPO service provider specializing in two business verticals financial services and retail and manufacturing It is claimed to be engaged in providing solutions that do not just reduce cost, but help the clients in....