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1. Rampgreen Solutions private Limited Vs Commissioner of Income tax(ITA 102/2015)

4. The Ld. D.R. stated that on perusa l of the annual report by Ld. DRP, he noted that this company is engaged in business process management services to organizations that outsource their business processes. Further, at P.60, under Note 2.25 -Segment Reporting, it is clearly stated that the company's operations primarily relate to providing business process management services, and accordingly revenues represented along with industry classes comprise the primary basis of segmental information. Thus, primary business activity of this company is business process management services, in various verticals such as FSI, MFG, RCL, ECS. At P.63 of annual report, Note 2.33, the report clearly states that as per function wise classification it has income from business process management services. On page 28 of the AR, in para 1.3 it is mentioned that Infosys BPO offers business outsourcing solutions to several clients and span across multiple industry segments. The company's catering to a variety of industries does not change the nature of functions carried out as it is committed to provide best in class services to both horizontal and vertical focus areas. Just because the company is providing cloud-based services over various mainframe computers, the company would not be functionally different as claimed by the assessee. In view of the above information in the annual report, there is no merit in the plea that this company is functionally different, and that it has diversified activities, and the arguments of Ld. A.R. to be dismissed.