The Tribunal held as
under:
1) Classification of ITES into low-end BPO services and high-end KPO
services for comparability analysis would not be fair and proper;
2) The companies providing mainly high-end services by using specialized
knowledge and domain expertise couldn’t be considered as comparable for
assessee-company, which was engaged in providing low end back office support
services (like voice or data processing services) to its AE;
3) Therefore, these entities (i.e. companies providing high end services)
could not be taken as comparable to the assessee-company which was mainly
involved in providing low-end services. - Maersk
Global Centres (India) (P.) Ltd. v. ACIT [2014] 43 taxmann.com 100
(Mumbai - Trib.) (SB)
3)
