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Highly technical service co. is not comparable to marketing support service provider

January 15, 2019[2019] 101 118 (Delhi - Trib.)

IT/ILT: A company engaged in highly technical services which included Asset Reconstruction and management services, projects related services, etc., was functionally dissimilar to marketing support services provider

IT/ILT: Where a company was a commercial testing house engaged in testing of various products including chemicals and also offered consultancy services in field of pollution control, it was functionally different from marketing support services provider

IT/ILT: Where high-end consultancy company which worked on engineering projects and was also a Government company, was incomparable to company rendering marketing support services

IT/ILT: Company engaged in business of rendering market research and management consulting services in field of IT, telecommunications and consumer technology could not be compared to marketing support services provider

IT/ILT: Where revenues of a company comprised of revenues from online advertising and fee based services which was not at par with marketing support services of assessee, it should be excluded from comparability analysis

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