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The Commissioner Of Income Tax -4 vs Ge India Business Services Pvt. Ltd. on 18 July, 2023 cites

Rampgreen Solutions Pvt Ltd vs Commissioner Of Income Tax on 10 August, 2015

[See judgment dated 10.08.2015 passed in ITA No.102/2015 titled Rampgreen Solutions Pvt. Ltd. Vs. Commissioner of Income Tax]. As would be evident from the aforesaid observations, the functional profile of the respondent/assessee is not similar to Rampgreen. The respondent/assessee is a BPO, and has been set up as a captive service provider for provisioning outsourcing services to GE Group companies. It provides ITES and Financial Support Services [FSS]. Therefore, it cannot be held that Rampgreen has a functional profile which is similar to that of the respondent/assessee.
Delhi High Court Cites 15 - Cited by 158 - V Bakhru - Full Document

M/S. Rampgreen Solutions Pvt. Ltd., ... vs Dcit, New Delhi on 24 March, 2023

the said comparable, once again, on the ground that there was functional dissimilarity, without giving any reasons. The Tribunal had relied upon the judgment rendered by it in Rampgreen Solutions Pvt. Ltd. vs DCIT Circle 20(2) dated 04.11.2015 ["Rampgreen Solutions Pvt. Ltd."], wherein it was observed that TCS International was providing software development services and therefore, was not functionally similar to Rampgreen, which was engaged in provisioning non-development software services.
Income Tax Appellate Tribunal - Delhi Cites 32 - Cited by 2 - G S Pannu - Full Document

Li And Fung India Pvt. Ltd. vs Commissioner Of Income Tax on 16 December, 2013

(iii) The Tribunal, while seeking to ascertain functional similarity to determine the ALP by using the TNMM Method should have borne in mind, factors referred to in the provisions of Rule 10B of the Income Tax Rules, 1962 [in short, "Rules"]. In other words, the Tribunal should have also borne in mind, the business environment; the nature and functions performed by the tested party and comparable entities; value addition in respect of products and services provided by the parties; the business model; and the assets and resources employed. [See Li & Fung India Pvt. Ltd. Vs. CIT, 361 ITR 85 (Delhi)].
Delhi High Court Cites 35 - Cited by 34 - S R Bhat - Full Document
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