determine the ALP of its international transaction of provision of legal
process outsourcing services to the AE.
19. The relevant methodology of TNMM as contained
Techno Analytics Ltd, M/s Informed Technologies Ltd. &
M/s Nittany Outsourcing Services Ltd. as comparables for determining the arm's
length price ... relevant factor in choosing Services (India) (P.) Ltd., company has outsourced
comparable cases is to find out (2017) 88 taxmann
erred In considering Crossdomain Solutions Private
Limited and E4e (earlier Nittany Outsourcing Services
Limited) as comparables without appreciating that the
functional asset and risk profile ... fact that the company has very low
employee cost implying that it outsources a major portion
of its work to third party vendors and hence
noticed that Capita,
UK was selected by Prudential, UK as strategic outsourcing partner and accordingly
the entire value of the deal was fixed ... saving of $60 million to Prudential by the year 2010. The
strategic outsourcing was mainly to administer 7 millions matured life and pension
policies including
assessee submit that Accentia is
engaged in software development and Knowledge Process Outsourcing
('KPO') services in the nature of healthcare revenue cycle management ... legal process outsourcing services. However, no separate
segmental information is available for the software development and
healthcare services provided by the company. Thus
countries, the „Cocteau agreement‟ which
is typical of any other outsourcing contract contained detailed
framework for providing adequate safeguards to SCB and the
requisite services ... performed by the assessee at certain
standards so as to meet the outsourcing objectives of SCB. He
also pointed out that the Reserve Bank
respect of high end services such as content development and
knowledge process outsourcing (KPO),which were very high. In relation to Maple
E solution ... call centre. These were providing high end services such as
Knowledge Process Outsourcing (KPO), Software Development etc. It was argued
that the assessee was operating
2398/Mum/2017
SBI Life Insurance Company Ltd.
the assessee by incurring outsourcing fee operation and
record storage expenses as data sorting, scanning, retrieving ... agree with the
appellant that in respect of these services/works
outsourced, it cannot be said that the these parties
have rendered any managerial, technical
that
the ld.AR argued that Eclerx Services Limited is engaged in outsourcing
activity predominantly, whereas the assessee is having its own infrastructure ... Number 1 Financial Services KPO and featured in the
Black Book of Outsourcing top 50 outsourcers. Brown & Wilson
(part of the Datamonitor Group) conducts
Transfer Pricing Officer
characterized the assessee as Knowledge Process Outsourcing (KPO) services and
rejected the assessee's transfer pricing study. He accepted/included Vishal ... earlier assessment years. The entities dealing with the
knowledge and processing outsourcing are not comparable to the assessee and hence need
to be excluded
