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Person engaged in specific skill based analysis including knowledge management system couldn’t be held as BPO

August 10, 2018[2018] 96 taxmann.com 237 (Delhi)

IT/ILT : A company engaged in advising functions of raising of funds and deploying same as fund manager could not be selected as comparable to research and development service provider

IT/ILT : Where company operations mainly related to providing asset management services and portfolio management services, it could not be selected as comparable to R and D services

IT/ILT : Where company provided a one-stop financial advisory and fund raising solutions in Investment Banking, Capital Markets, Wealth Management Project Finance and Growth stage investing, it was incomparable to R and D service provider

IT/ILT : Where assessee-company rendered research and information services which were inclusive of infrastructure support, application support, application operations and group and survey development services to its AE, it was rendering knowledge based service and was required to be benchmarked with comparables engaged in research services and not BPO services

IT/ILT : If there is any delay in realization of a trading debt arising from sale of goods or services rendered in course of carrying on of business, assessee is liable to be visited with transfer pricing adjustment on account of interest income short charged/uncharged

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