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Co. engaged in providing KPO services not to be taken as comparable if assessee was rendering ITES to AE

December 10, 2018[2019] 101 taxmann.com 117 (Bombay)
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IT/ILT: Where assessee was rendering ITES services to AE, a company which outsourced services to be rendered by it and thereby followed a different business model, could not be accepted as comparable

IT/ILT: In case of assessee rendering ITES services to AE, a company in whose case extraordinary event of amalgamation took place during relevant year, was not acceptable as comparable

IT/ILT: Where assessee was rendering ITES services to AE, a company engaged in providing KPO services, could not be accepted as comparable

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