Maersk Global Service Centre India ... vs Asst Cit 15(2)(2), Mumbai on 5 February, 2020
9.3 From the perusal of the annual report for the year ended 31/03/2014 of
the said comparable, we find from page 707 of the paper book that the said
comparable had incurred outsourcing cost of Rs. 1078.76 Crores which is
included under the head "miscellaneous expenses" which goes to prove that
it has got a different business model. From the various functions performed
by MPS Ltd., we find that the said comparable is predominantly in the
business of digital publishing which cannot be treated at par with ITeS
which is the case of the assessee in ITeS segment. In this regard, we find
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Maers k G lobal Servi ce Cen tres Ind ia Pvt. Ltd
that the reliance placed by the ld. AR on the Co-ordinate Bench decision of
Bangalore Tribunal in the case of Google (India) (P). Ltd., v. Dy DCIT
[2013] 29 taxmann.com 412/55 SOT 489 is well founded wherein it was
held as under:--