Rampgreen Solutions Pvt. Ltd. v. CIT

377 ITR 533High Court2015#660 most cited

What is Rampgreen Solutions Pvt. Ltd. v. CIT authority for?

Knowledge Process Outsourcing (KPO) service providers are functionally dissimilar to Business Process Outsourcing (BPO) or Information Technology Enabled Services (ITeS) providers and cannot be compared for transfer pricing purposes, even under the Transactional Net Margin Method (TNMM). Further, companies with significantly different business models, such as those with extensive subcontracting, should be excluded as comparables.

150

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

Rampgreen Solutions Pvt. Ltd. v. CIT · 377 ITR 533 · Section 92C(2) · Transfer Pricing · comparable companies · KPO BPO functional dissimilarity · Transactional Net Margin Method · TNMM · business model difference · subcontracting · Section 10A · Section 10B

Also reported as

279 CTR 441

Sections most often in play

Section 10B(3)Section 133(6)Section 10B(2)(a)Section 234BSection 10(B)(3)Section 108(1)(e)Section 10ASection 10B(1)(e)
Read the full judgment

Issues it is cited on

captive service providersection 92c(2)resulting companyworking capital adjustmenttransactional net margin methodfar analysisrelated party transactiondemergercomparable companiestested partystrategic investmentamalgamation

Judgments citing Rampgreen Solutions Pvt. Ltd. v. CIT

GBT INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT,OSD, DELHI

In the result, the assessee’s appeal is allowed as above

ITA 1764/DEL/2022[2018-19]Status: DisposedITAT Delhi26 Nov 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 143(3)Section 234ASection 36(1)(vii)Section 36(2)

…itted that a KPO service provider was functionally different from BPO service providers (like the appellant assessee) and this distinction was well GBT India Pvt. Ltd. recognized by the Hon’ble High Court of Delhi in the case of Rampgreen Solutions (P.) Ltd. 377 ITR 533, wherein it had been specifically held that KPO service providers could not be compared to BPO service providers even under TNMM. The Ld. Counsel contended that the assessee’s functions were different as it was a Business Process Outsourcing (BPO). Thus, it was contended that this comparable was functionally dissimilar. It was also submitted that…

ACIT, CIRCLE- 9(1), NEW DELHI vs. FIS GLOBAL BUSINESS SOLUTIONS INDIA PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue and CO of the assessee are partly allowed as above for statistical purposes

ITA 372/DEL/2018[2009-10]Status: DisposedITAT Delhi25 Aug 2025AY 2009-10

Bench: Shri Sudhir Pareek & Shri Avdhesh Kumar Mishra

…rent being engaged in providing KPO services such as data analytics, operation management services and audit reconciliation services. The Ld. CIT(A), placing reliance on the decision of the Hon’ble Delhi High Court in the case of Rampgreen Solutions Pvt. Ltd. 377 ITR 533, excluded this comparable on the following reasoning: a) Functional dissimilarities: This comparable provides data analytics, and data process solutions, whereas the assessee has provided ITeS services in the nature of financial shared services, data entry and call center services. b) Abnormal growth of this comparable on account of extra ordinar…

DCIT, NEW DELHI vs. M/S. FIS GLOBAL BUSINESS SOLUTIONS INDIA PVT. LTD., NEW DELHI

In the result, both appeals of the revenue stand dismissed and both Cos are allowed as above

ITA 2387/DEL/2014[2008-09]Status: DisposedITAT Delhi09 May 2025AY 2008-09

Bench: SHRI AVDHESH KUMAR MISHRA (Accountant Member)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I’: NEW DELHI BEFORESHRISUDHIR KUMAR, JUDICIAL MEMBER AND SHRI AVDHESH KUMAR MISHRA, ACCOUNTANT MEMBER ITA No.5939/Del./2012, A.Y. 2007-08 ITA No.2387/Del./2014, A.Y. 2008-09 Dy. Commissioner FIS Global Business Solution India of Income Tax, (P) Ltd.[formerly known as E-Funds Circle 11(1), Vs. International India (P) Ltd.] Room No. 312, S-405 (LGF), Greater Kailash, Part-II C.R.Building, New Delhi-110048 New Delhi PAN: AAACH2815H (Appellant) (Respondent) C.O. No. 03/Del/2013 (Arising out of ITA No.5939/Del./2012, A.Y. 2007-08) C.O. No. 02/Del/2015 (Arising out o…

DCIT, NEW DELHI vs. FIS GLOBAL BUSINESS SOLUTION INDIA (P) LTD., NEW DELHI

In the result, both appeals of the revenue stand dismissed and both Cos are allowed as above

ITA 5939/DEL/2012[2007-08]Status: DisposedITAT Delhi09 May 2025AY 2007-08

Bench: SHRISUDHIR KUMAR (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I’: NEW DELHI BEFORESHRISUDHIR KUMAR, JUDICIAL MEMBER AND SHRI AVDHESH KUMAR MISHRA, ACCOUNTANT MEMBER ITA No.5939/Del./2012, A.Y. 2007-08 ITA No.2387/Del./2014, A.Y. 2008-09 Dy. Commissioner FIS Global Business Solution India of Income Tax, (P) Ltd.[formerly known as E-Funds Circle 11(1), Vs. International India (P) Ltd.] Room No. 312, S-405 (LGF), Greater Kailash, Part-II C.R.Building, New Delhi-110048 New Delhi PAN: AAACH2815H (Appellant) (Respondent) C.O. No. 03/Del/2013 (Arising out of ITA No.5939/Del./2012, A.Y. 2007-08) C.O. No. 02/Del/2015 (Arising out o…

ICICI BANK LTD,MUMBAI vs. ADDL CIT RG 3 (1), MUMBAI

ITA 4249/MUM/2014[2008-09]Status: DisposedITAT Mumbai30 Apr 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Omkareshwar Chidara

For Appellant: Arati VissanjiFor Respondent: Shri Ajay Chandra, CIT/DR
Section 10(15)Section 14ASection 250Section 36(1)(vii)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “H”, MUMBAI BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND SHRI OMKARESHWAR CHIDARA, ACCOUNTANT MEMBER ITA No.4249/Mum/2014 Assessment Year: 2008-09 ICICI Bank Limited DCIT, Circle-3(1), Aayakar Bhawan, ICICI Bank Towers, North East Mumbai Wing, 1st Floor, Bandra Kurla vs. Complex, Bandra (East), Mumbai 400034. PAN: AAACI 1195 Η (Appellant) (Respondent) ITA No.4159/Mum/2014 Assessment Year: 2008-09 ICICI Bank Limited DCIT, Circle-3(1), Aayakar Bhawan, Mumbai (Appellant) vs. ICICI Bank Towers, North East Wing, 1st Floor, Bandra Kurla Complex, Bandra (East), Mumba…

DCIT CIR 3(1), MUMBAI vs. ICICI BANK LTD, MUMBAI

ITA 4159/MUM/2014[2008-09]Status: DisposedITAT Mumbai30 Apr 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Omkareshwar Chidara

For Appellant: Arati VissanjiFor Respondent: Shri Ajay Chandra, CIT/DR
Section 10(15)Section 14ASection 250Section 36(1)(vii)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “H”, MUMBAI BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND SHRI OMKARESHWAR CHIDARA, ACCOUNTANT MEMBER ITA No.4249/Mum/2014 Assessment Year: 2008-09 ICICI Bank Limited DCIT, Circle-3(1), Aayakar Bhawan, Mumbai ICICI Bank Towers, North East Wing, 1st Floor, Bandra Kurla vs. Complex, Bandra (East), Mumbai - 400034. (Appellant) PAN: AAACI 1195 Η (Respondent) ITA No.4159/Mum/2014 Assessment Year: 2008-09 ICICI Bank Limited DCIT, Circle-3(1), Aayakar Bhawan, Mumbai (Appellant) vs. ICICI Bank Towers, North East Wing, 1st Floor, Bandra Kurla Complex, Bandra (East), Mum…

DCIT, NEW DELHI vs. M/S. SONY INDIA PVT. LTD., NEW DELHI

In the result, appeal filed by the assessee is partly allowed as indicated above and appeal filed by the revenue is dismissed

ITA 1166/DEL/2015[2010-11]Status: DisposedITAT Delhi30 Aug 2024AY 2010-11

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143Section 143(2)Section 143(3)Section 92C

…t page 176 of the Annual Report PB. Item 11 at page 174 would show that subcontracting work was got done of INR 372 crores (this by itself shows a different business model) which by itself warrants exclusion as per Rampgreen Solutions Pvt. ltd. vs. CIT (2015) 377 ITR 533 - Para 38.Segmental details are not available in the financials as can be seen from page 183 of the Annual Report PB. All these factors have been taken into account in Sony Mobile Communications International AB in relation to assessment year AY 2010-11 as also in the case of Kaplan India Pvt. Ltd vs ITO., ITA No. 1481/Del/2015 placed at pages 72…

SONY INDIA PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, NEW DELHI

In the result, appeal filed by the assessee is partly allowed as indicated above and appeal filed by the revenue is dismissed

ITA 1026/DEL/2015[2010-11]Status: DisposedITAT Delhi30 Aug 2024AY 2010-11

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143Section 143(2)Section 143(3)Section 92C

…t page 176 of the Annual Report PB. Item 11 at page 174 would show that subcontracting work was got done of INR 372 crores (this by itself shows a different business model) which by itself warrants exclusion as per Rampgreen Solutions Pvt. ltd. vs. CIT (2015) 377 ITR 533 - Para 38.Segmental details are not available in the financials as can be seen from page 183 of the Annual Report PB. All these factors have been taken into account in Sony Mobile Communications International AB in relation to assessment year AY 2010-11 as also in the case of Kaplan India Pvt. Ltd vs ITO., ITA No. 1481/Del/2015 placed at pages 72…

PRIMETALS TECHNOLOGIES INDIA PVT. LTD.,KOLKATA vs. ACIT, CIRCLE - 1(1), KOLKATA, KOLKATA

In the result, appeals of the assessee for Assessment Year 2017-18

ITA 372/KOL/2022[2018-2019]Status: DisposedITAT Kolkata16 May 2024AY 2018-2019

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 371 & 372/Kol/2022 Assessment Year: 2017-18 & 2018-19 Primetals Technologies India Pvt. Ltd. Acit, Circle-1(1), Kolkata 5Th Floor, Tower-C Vs Dlf, It Park-I 08 Majore Arterial Road New Town Kolkata - 700156 [Pan : Aaecv9657M] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ajoy Vora, Sr. Advocate & Pooja Saraf, Ar Revenue By : Shri Rakesh Kumar Das, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 21/02/2024 घोषणा क" तारीख /Date Of Pronouncement: 16/05/2024 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeals Are Directed At The Instance Of The Assessee Against The Final Assessment Orders Framed U/S 143(3) R.W.S. 144C & 144C(5) Of The Income Tax Act, 1961 (Hereinafter ‘The Act’) By The Deputy Commissioner Of Income Tax, Circle – 1(1), Kolkata (Hereinafter The “Ld. Ao”) Even Dt. 29/04/2022, Passed In Pursuance Of The Directions Of The Ld. Dispute Resolution Panel -2, New Delhi, Dt. 18/02/2022 For Assessment Year 2017-18 & Dt. 04/03/2022 For Assessment Year 2018-19, Passed U/S 144C(5) Of The Act. 2. The Assessee Has Raised The Following Grounds Of Appeal For Assessment Year 2017-18:- “Ground 1:

For Appellant: Shri Ajoy Vora, Sr. Advocate and Pooja Saraf, ARFor Respondent: Shri Rakesh Kumar Das, CIT, D/R
Section 143(3)Section 144CSection 144C(5)Section 156Section 32(1)Section 92C

…rovide. It prima facie indicate that the specific characteristic of services and products sold by BGR Energy System Ltd. and the assessee company are significantly different. Hon’ble Delhi High Court in the case of Rampgreen Solutions Pvt. Ltd. vs. CIT [2015] 377 ITR 533 (Del) held that comparability analysis should be undertaken on the basis of functional profile and characteristics of services provided. Respectfully following the same, we hold that as the functional profile of BGR Energy System Ltd. is significantly different from the assessee company, the ld. AO erred in including the same as comparable for ca…

PRIMETALS TECHNOLOGIES INDIA PRIVATE LIMITED,KOLKATA vs. ACIT, CIRCLE-1(1), KOLKATA, KOLKATA

In the result, appeals of the assessee for Assessment Year 2017-18

ITA 371/KOL/2022[2017-2018]Status: DisposedITAT Kolkata16 May 2024AY 2017-2018

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 371 & 372/Kol/2022 Assessment Year: 2017-18 & 2018-19 Primetals Technologies India Pvt. Ltd. Acit, Circle-1(1), Kolkata 5Th Floor, Tower-C Vs Dlf, It Park-I 08 Majore Arterial Road New Town Kolkata - 700156 [Pan : Aaecv9657M] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ajoy Vora, Sr. Advocate & Pooja Saraf, Ar Revenue By : Shri Rakesh Kumar Das, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 21/02/2024 घोषणा क" तारीख /Date Of Pronouncement: 16/05/2024 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeals Are Directed At The Instance Of The Assessee Against The Final Assessment Orders Framed U/S 143(3) R.W.S. 144C & 144C(5) Of The Income Tax Act, 1961 (Hereinafter ‘The Act’) By The Deputy Commissioner Of Income Tax, Circle – 1(1), Kolkata (Hereinafter The “Ld. Ao”) Even Dt. 29/04/2022, Passed In Pursuance Of The Directions Of The Ld. Dispute Resolution Panel -2, New Delhi, Dt. 18/02/2022 For Assessment Year 2017-18 & Dt. 04/03/2022 For Assessment Year 2018-19, Passed U/S 144C(5) Of The Act. 2. The Assessee Has Raised The Following Grounds Of Appeal For Assessment Year 2017-18:- “Ground 1:

For Appellant: Shri Ajoy Vora, Sr. Advocate and Pooja Saraf, ARFor Respondent: Shri Rakesh Kumar Das, CIT, D/R
Section 143(3)Section 144CSection 144C(5)Section 156Section 32(1)Section 92C

…rovide. It prima facie indicate that the specific characteristic of services and products sold by BGR Energy System Ltd. and the assessee company are significantly different. Hon’ble Delhi High Court in the case of Rampgreen Solutions Pvt. Ltd. vs. CIT [2015] 377 ITR 533 (Del) held that comparability analysis should be undertaken on the basis of functional profile and characteristics of services provided. Respectfully following the same, we hold that as the functional profile of BGR Energy System Ltd. is significantly different from the assessee company, the ld. AO erred in including the same as comparable for ca…

CRISIL LTD,MUMBAI vs. ASST CIT RG 9(2)(2), MUMBAI

ITA 1345/MUM/2017[2012-13]Status: DisposedITAT Mumbai10 Jan 2024AY 2012-13
Section 133(6)Section 144C(5)

…or Your\nHonours ready reference -Para no. 26, Pg. nos, 28-29:\n\"4. As far as the exclusion of ESL is concerned, the ITAT appears to\nhave relied upon para 31 of the decision of this Court in\nRampgreen Solutions Pvt Ltd u. Commissioner of Income Tax\n(2015) 377 ITR 533 (Del). The ITAT has extracted para 31 of the\nsaid decision where inter alia the Court pointed out that:\n\"We find it difficult to accept this view as it is contrary to the\nfundamental rationale of determining ALP by comparing\ncontrolled transactions/entities with similar uncontrolled\ntransactions/entities. ITeS encompasses a wide spectrum of…

CRISIL LTD,MUMBAI vs. DCIT 9(2)(2), MUMBAI

ITA 997/MUM/2016[2011-12]Status: DisposedITAT Mumbai10 Jan 2024AY 2011-12
Section 133(6)Section 144C(5)

…or Your\nHonours ready reference -Para no. 26, Pg. nos, 28-29:\n\"4. As far as the exclusion of ESL is concerned, the ITAT appears to\nhave relied upon para 31 of the decision of this Court in\nRampgreen Solutions Pvt Ltd u. Commissioner of Income Tax\n(2015) 377 ITR 533 (Del). The ITAT has extracted para 31 of the\nsaid decision where inter alia the Court pointed out that:\n\"We find it difficult to accept this view as it is contrary to the\nfundamental rationale of determining ALP by comparing\ncontrolled transactions/entities with similar uncontrolled\ntransactions/entities. ITeS encompasses a wide spectrum of…

CRISIL LTD,MUMBAI vs. ASST CIT RG 9(2)(2), MUMBAI

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 1114/MUM/2015[2010-11]Status: DisposedITAT Mumbai10 Jan 2024AY 2010-11

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 133(6)Section 144C(5)

…nder for Your Honours ready reference -Para no. 26, Pg. nos, 28-29: "4. As far as the exclusion of ESL is concerned, the ITAT appears to have relied upon para 31 of the decision of this Court in Rampgreen Solutions Pvt Ltd u. Commissioner of Income Tax (2015) 377 ITR 533 (Del). The ITAT has extracted para 31 of the said decision where inter alia the Court pointed out that: "We find it difficult to accept this view as it is contrary to the fundamental rationale of determining ALP by comparing controlled transactions/entities with similar uncontrolled transactions/entities. ITeS encompasses a wide spectrum of servi…

CRISIL LTD,MUMBAI vs. DCIT (OSD) 8(1), MUMBAI

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 1564/MUM/2014[2009-10]Status: DisposedITAT Mumbai10 Jan 2024AY 2009-10

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 133(6)Section 144C(5)

…nder for Your Honours ready reference -Para no. 26, Pg. nos, 28-29: "4. As far as the exclusion of ESL is concerned, the ITAT appears to have relied upon para 31 of the decision of this Court in Rampgreen Solutions Pvt Ltd u. Commissioner of Income Tax (2015) 377 ITR 533 (Del). The ITAT has extracted para 31 of the said decision where inter alia the Court pointed out that: "We find it difficult to accept this view as it is contrary to the fundamental rationale of determining ALP by comparing controlled transactions/entities with similar uncontrolled transactions/entities. ITeS encompasses a wide spectrum of servi…

DCIT RG (OSD) 8(1), MUMBAI vs. CRISIL LTD, MUMBAI

ITA 1180/MUM/2014[2009-10]Status: DisposedITAT Mumbai10 Jan 2024AY 2009-10
Section 133(6)Section 144C(5)

…or Your\nHonours ready reference -Para no. 26, Pg. nos, 28-29:\n\"4. As far as the exclusion of ESL is concerned, the ITAT appears to\nhave relied upon para 31 of the decision of this Court in\nRampgreen Solutions Pvt Ltd u. Commissioner of Income Tax\n(2015) 377 ITR 533 (Del). The ITAT has extracted para 31 of the\nsaid decision where inter alia the Court pointed out that:\n\"We find it difficult to accept this view as it is contrary to the\nfundamental rationale of determining ALP by comparing\ncontrolled transactions/entities with similar uncontrolled\ntransactions/entities. ITeS encompasses a wide spectrum of…

CRISIL LTD,MUMBAI vs. ADDL CIT 8(1), MUMBAI

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 7603/MUM/2012[2008-09]Status: DisposedITAT Mumbai10 Jan 2024AY 2008-09

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 133(6)Section 144C(5)

…nder for Your Honours ready reference -Para no. 26, Pg. nos, 28-29: "4. As far as the exclusion of ESL is concerned, the ITAT appears to have relied upon para 31 of the decision of this Court in Rampgreen Solutions Pvt Ltd u. Commissioner of Income Tax (2015) 377 ITR 533 (Del). The ITAT has extracted para 31 of the said decision where inter alia the Court pointed out that: "We find it difficult to accept this view as it is contrary to the fundamental rationale of determining ALP by comparing controlled transactions/entities with similar uncontrolled transactions/entities. ITeS encompasses a wide spectrum of servi…

EVEREST BUSINESS ADVISORY INDIA PVT. LTD.,,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal is partly allowed

ITA 1907/DEL/2016[2010-11]Status: DisposedITAT Delhi29 Nov 2023AY 2010-11

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 2010-11 . Everest Business Advisory Vs. Acit, India Pvt. Ltd., Circle-11(1), A-1/B-27, Janak Puri, New Delhi New Delhi Pan :Aabce2871R (Appellant) (Respondent)

…ion Technology segment for comparability purpose, however, that segment cannot be a comparable, as, the assessee is rendering low end ITES. In support of such contention, she relied upon the following decisions: 1. Rampgren Solutions (P) Ltd. Vs. CIT [2015] 279 CTR 441 (Delhi HC) 2. Open Solutions Software Services (P.) Ltd. [2020] 116 taxmann.com 708 (Delhi HC) 3. NTT Data Global Delivery Services Ltd. Vs. ITO [2020] 117 taxmann.com 92 (Delhi – Trib.) 4. MD Everywhere India (P) Ltd. Vs. DCIT [2022] 139 taxmann.com 577 (Delhi – Trib.) 5. Jr. CIT Vs. Steria India (P) Ltd. [2021] 123 taxmann.com 264 (Delhi – Trib…

ACIT, CIRCLE- 21(1), NEW DELHI vs. RESERVATION DATE MAINTENANCE INDIA (P) LTD., NEW DELHI

In the result, appeal of Revenue is dismissed

ITA 3539/DEL/2018[2011-12]Status: DisposedITAT Delhi20 Nov 2023AY 2011-12

Bench: the CIT(A). Before the CIT(A), the assessee assailed the comparables newly selected by the TPO and rejection of comparables selected by assessee for computing Arm’s Length Price (ALP) by disturbing the TP study of the assessee. The CIT(A) took note of the detailed submissions made on behalf of the assessee and found merit in the plea of the assessee. The relevant operative para of the order of the CIT(A) is reproduced hereunder:

Section 143(3)Section 92C

…ble selected by the AO/TPO is not justified. Similar view has been taken by the Co-ordinate Bench in assessee’s own case in A.Y. 2010-11 in ITA No.5351/Del/2017 order dated 16.10.2023. Accentia being KPO as held in Rampgreen Solutions (P.) Ltd. vs. CIT [2015] 377 ITR 533 (Delhi) and quite different from the BPO profile of the assessee, we see no error in the conclusion drawn by the CIT(A) for rejecting this comparable. 8. Second comparable in dispute is ‘Eclerx Services Limited’. The Co-ordinate Bench in A.Y. 2010-11 in assessee’s own case observed that activities of ‘Eclerx’ is that of a KPO providing specializ…

ICICI BANK LTD,MUMBAI vs. ADDL CIT RG (1), MUMBAI

Appeals are partly allowed

ITA 4248/MUM/2014[2007-08]Status: DisposedITAT Mumbai09 Nov 2023AY 2007-08

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Section 10(15)Section 115JSection 234BSection 41(4)Section 88ESection 90

…on to deviate from the order of the co-ordinate bench in assessee's own case for earlier years. Further, the Delhi High Court had also an occasion to consider the exclusion of Vishal information technologies Ltd. in Rampgreen Solutions (P.) Ltd. v. CIT [2015] 377 ITR 533/234 Taxman 573/60 taxmann.com 355 (Delhi) wherein, the High Court has held that this comparable could not be considered, as a comparable because of its business model was completely different. In view of the decision of the Delhi High Court as well as the decision of the co-ordinate bench in assessee's own case, the Assessing Officer/TPO was to b…

DCIT CIR 3(1), MUMBAI vs. ICICI BANK LTD, MUMBAI

Appeals are partly allowed

ITA 4158/MUM/2014[2007-08]Status: DisposedITAT Mumbai09 Nov 2023AY 2007-08

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Section 10(15)Section 115JSection 234BSection 41(4)Section 88ESection 90

…on to deviate from the order of the co-ordinate bench in assessee's own case for earlier years. Further, the Delhi High Court had also an occasion to consider the exclusion of Vishal information technologies Ltd. in Rampgreen Solutions (P.) Ltd. v. CIT [2015] 377 ITR 533/234 Taxman 573/60 taxmann.com 355 (Delhi) wherein, the High Court has held that this comparable could not be considered, as a comparable because of its business model was completely different. In view of the decision of the Delhi High Court as well as the decision of the co-ordinate bench in assessee's own case, the Assessing Officer/TPO was to b…

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