LIONBRIDGE TECHNOLOGIES PVT LTD VS ITO [2014] 48 TAXMANN.COM 46 (MUMBAI – TRIB.)The Tribunal held that comparables providing KPO services like engineering or data analysis/processing etc cannot be comparable with the assessee engaged in providing low end back-office operations.

The assessee was engaged in providing low end back-office support services. During AY 2007-08, the assessee had entered international transaction of rendering IT & ITES services to its AEs. TNMM was adopted as MAM. Relying on the case of Maersk Global Centres (India) (P.) Ltd. v. ACIT [2014] 147 ITD 83/43 100 (Mum. – Trib), the ITAT held that, Mold-Tek Technologies Ltd is into providing KPO engineering services and should be excluded on basis of functionality. Eclerx Services Ltd is a KPO engaged in providing data analysis and data process solutions, online operation support, customer relationship management support, data de-duplication services etc., and is to be rejected on the ground that it functionally different.

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