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4. The assessee M/s. vCustomer Services India Pvt. Ltd. [for short vCustomer India] is a wholly owned subsidiary of vCustomer US. M/s. vCustomer India is primarily engaged in providing IT enabled services to its parent company vCustomer US. The assessee has the expertise in providing process driven quality centric Business Process Outsourcing [BPO] services, contract centre and technology enabled services through its state of art facilities located in two cities in India, namely, New Delhi and Pune. The following international transactions have been entered into by the assessee with its Associated Enterprise [AE].

"Functionally different. This is functionally different company Notes to accounts annual report for year ended 31.03.2011 states:
"BACK GROUND: The Company was incorporated on July 27, 1992 as Computer Exchange Private Limited (CEPL) and subsequently became wholly owned subsidiary of ICRA Limited August 25. 2005 and was renamed as ICRA Techno Analytics Limited (ICTEAS). The company is engaged in the software development & consultancy..engineering services, web development & hosting and subsequently diversified itself into the domain of business analytics and business process outsourcing." (Pg 231/91) Revenue recognition. In the note detailing of the revenue recognition which also form a part of its annual report it has been stated that its revenue stream consisted of software development consultancy, engineering services, web development and hosting.

27. The ld. Counsel further submits that this company has been excluded by the Bangalore bench of the Tribunal in the case of Cerner Healthcare Solutions (P.) Ltd. Vs. ITO [(2017) 79 taxmann.com 64 (Bangalore - Trib.) for assessment year 2010-11 for the reason that ICRA Techno Analytics Ltd. was into diversified activities, software development, consultancy and engineering services, web development and hosting and subsequently diversified into business analysis and business processing outsourcing and, therefore, it is not functionally comparable with that of the assessee. The ld. Counsel further submits that similar view has been taken by the Bangalore Bench of the Tribunal in the case of Applied Material India (P.) Ltd. [73 taxmann.com 160].

"1. Background and principal activities. TCS e-Serve Limited is engaged in the business of providing information Technology-
Enabled Services (ITES) /Business Process Outsourcing (BPO) services, primarily to Citigroup entities globally. The company's operations broadly comprise of transaction processing and technical services. Transaction processing includes the broad spectrum of activities involving the processing, collections, customer care and payments in relation to the services offered by Citigroup of its corporate and retail clients. Technical services involve software testing, and validation of software at the time of implementation and data centre management activities." (Pg. 525/FS-II) This comparable functionally has TWO business segments; namely, 'Transaction Process Services' to bank and 'Technical Services', like its subsidiary, 'TCS e-Serve International Ltd.' Segmental details however are not available.