Search Results Page
Search Results
1 - 6 of 6 (0.25 seconds)The Income Tax Act, 1961
Section 139 in The Income Tax Act, 1961 [Entire Act]
Section 144C in The Income Tax Act, 1961 [Entire Act]
S & P Capital Iq (India) Private Limited, ... vs Dcit, International Taxation-2, ... on 7 March, 2023
4.1. Ld.TPO considered this as a comparable. Assessee objects to
the compatibility of this company is due to functional
incompatibility. Ld.AR submitted that this company was having
supernormal profit and is engaged in providing KPO services
which is distinct from the nature of services provided by the
assessee before us. He has placed reliance upon the decision of
coordinate benches of this tribunal in the case of M/s.Capital IQ
Information Systems (India) Pvt. Ltd. Vs. DCIT in ITA No.
1961/H/2011 and Symphony Marketing Solutions India Pvt. Ltd.,
in ITA No. 1316/BANG/2012, wherein the dissimilarities between
KPO services and BPO service has been drawn up. He further
contended similar view has been upheld by the Hon'ble
jurisdictional High Court in the case of Rampgreen Solutions Pvt.
Ltd., vs. CIT in ITA 102/2015.
Rampgreen Solutions Pvt Ltd vs Commissioner Of Income Tax on 10 August, 2015
4.1. Ld.TPO considered this as a comparable. Assessee objects to
the compatibility of this company is due to functional
incompatibility. Ld.AR submitted that this company was having
supernormal profit and is engaged in providing KPO services
which is distinct from the nature of services provided by the
assessee before us. He has placed reliance upon the decision of
coordinate benches of this tribunal in the case of M/s.Capital IQ
Information Systems (India) Pvt. Ltd. Vs. DCIT in ITA No.
1961/H/2011 and Symphony Marketing Solutions India Pvt. Ltd.,
in ITA No. 1316/BANG/2012, wherein the dissimilarities between
KPO services and BPO service has been drawn up. He further
contended similar view has been upheld by the Hon'ble
jurisdictional High Court in the case of Rampgreen Solutions Pvt.
Ltd., vs. CIT in ITA 102/2015.
1