TaxTMI 
TaxTMI 
2023 (10) TMI 1132
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....el (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 exclusion of Eclerx Services Limited from the final s....
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....truggles 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 consistency in data entry for Search Palace database; minimize duplication of effort; and maximize re-use of information and to mo....
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.... 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 skills required etc. The results of this activity may be included in the Search Palace. Business Development Research Business development research is business initiative for all the industry practices. This business initiative includes issuing News Alerts and compa....
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....ather 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 data base of prospective employers and candidates who sent their resumes to Hendrick & Struggles International Inc (HSI), the assessee provides services to HSII only having minimal risks whereas as per the information supplied by ECLERX u/s 133 (6), it is into data analytical services, operation management services; acc....
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.... 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 increase sales and reduce risk by enhancing efficiencies and by providing valuable insights that empower better decisions. M/s eClerx Services Pvt. Ltd is also claimed to have a scalable delivery model and solutions offered that include data analytics, operations management, audits and reconciliation, metrics management and reporting service....