How many judgments cite Rampgreen Solutions Pvt. Ltd. v. CIT?

196 judgments on BharatTax cite Rampgreen Solutions Pvt. Ltd. v. CIT (377 ITR 533), spanning 2016 to 2025.

Which sections of the Income Tax Act does Rampgreen Solutions Pvt. Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 10B(3), Section 133(6), Section 10B(2)(a), Section 234B, Section 10(B)(3), Section 108(1)(e).

Rampgreen Solutions Pvt. Ltd. v. CIT

377 ITR 533High Court2015#477 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.

196

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 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 234B Section 10(B)(3)Section 108(1)(e)Section 10A Section 10B(1)(e)

Read the full judgment

Issues it is cited on

captive service provider section 92c(2)resulting company working capital adjustment transactional net margin method far analysis related party transaction demerger comparable companies tested party strategic investment amalgamation

Judgments citing Rampgreen Solutions Pvt. Ltd. v. CIT

DCIT RG (OSD) 8(1), Mumbai vs. Crisil Ltd, Mumbai

ITA 1180/MUM/2014[2009-10]Status: DisposedITAT Mumbai10 Jan 2024AY 2009-10

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleιτα.Νο. 7603/Mum/2012 (A.Y: 2008-09) M/S. Crisil Limited 8Th Floor, Central Avenue Road Hiranandani Business Park Opp. D-Mart, Powai Mumbai- 400076 Pan: Aaaст3151E (Appellant) V. Addl. Cit - 8(1) Aayakar Bhavan, M.K. Road Mumbai- 400020 (Respondent) Ιτα.Νο. 1564/Mum2014 (A.Y: 2009-10) M/S. Crisil Limited Central Avenue Road Hiranandani Business Park Opp. D-Mart, Powai Mumbai- 400076 V. Dy. Cit (Osd) – 8(1) Aayakar Bhavan, M.K. Road Mumbai- 400020 (Respondent) Pan: Aaaст3151E (Appellant)

Section 133(6)Section 144C(5)Section 92C(2)

…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. 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)

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

DCIT, Circle-21(1), New Delhi vs. M/S. Reservation Data Maintenance India (P) Ltd., New Delhi

In the result, appeal of the Revenue is dismissed

ITA 5351/DEL/2017[2010-11]Status: DisposedITAT Delhi16 Oct 2023AY 2010-11

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasad

For Appellant: Shri Sandeep Yadav, AdvFor Respondent: Shri Manu Chaurasia

Section 92C(2)

…ctual property rights and goodwill as compared to the assessee. Therefore, in view of the above reasons this company is required to be excluded. Further relying on the decision of Jurisdictional high court in case of Rampgreen Solutions (P) Ltd. v. CIT [2015] 377 ITR 533 (Delhi) where in it is held that KPO are ITeS where the service providers have to employ advanced level of skills and knowledge. This is absent in this case of assessee which is low end ITES service provider such as which enables network management and other back office support services performed by assessee which primarily include remote monitor…

The Pr. Commissioner of Income Tax -4 vs. Ge India Business Services Pvt. Ltd

ITA/1215/2018HC Delhi10 Oct 2023

Bench: HON'BLE MR. JUSTICE RAJIV SHAKDHER,HON'BLE MR. JUSTICE GIRISH KATHPALIA

…ITA 1215/2018 Page 1 of 2 $~3 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Decision delivered on: 10.10.2023 + ITA 1215/2018 THE PR. COMMISSIONER OF INCOME TAX -4..... Appellant Through: Mr Prashant Meharchandani, Sr. Standing Counsel with Mr Akshat Singh, Jr. Standing Counsel and Ms Ritika Vohra, Adv. versus GE INDIA BUSINESS SERVICES PVT. LTD. ..... Respondent Through: Mr Sachit Jolly w…

Pr. Commissioner of Income Tax -7, Delhi vs. M/S Reservation Data Maintenance India Pvt. Ltd

ITA - 413 / 2023HC Delhi31 Jul 2023

…ue, contended that insofar as the exclusion of Eclerx Services Ltd. and Coral Hub Ltd. is concerned, the approach taken by the Tribunal is covered by the decision of the coordinate bench of this court rendered in Rampgreen Solutions (P.) Ltd. v. CIT [2015] 377 ITR 533 (Del). 13. Mr Rai, however, submitted that as regards the other two comparables, i.e., Accentia Technology Ltd. and Cosmic Global Ltd, the Tribunal has misdirected itself on facts and in law. 13.1 It is Mr Rai’s contention that there was functional similarity between the business of the respondent/assessee as well as the two comparabl…

Serco India Pvt. Ltd., Pune vs. DCIT, Gurgaon

In the result, appeal filed by the Assessee stands allowed

ITA 1432/DEL/2016[2011-12]Status: DisposedITAT Delhi27 Jun 2023AY 2011-12

Bench: Shrianil Chaturvedi, Am & Shri N. K. Choudhry, Jm

For Appellant: Sh. Suraj Bhan Nain, Ld. AdvFor Respondent: Sh. Rajesh Kumar, Ld. CIT (DR)

Section 143(3)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, DELHI BEFORE SHRIANIL CHATURVEDI, ACCOUNTANT MEMBER, AM & SHRI N. K. CHOUDHRY, JM I.T.A. No. 1432/Del/2016 Assessment Year: 2011-12) Serco India Pvt. Ltd. DCIT Circle-4(1), 3rd Floor, Vanijya Nikunj, C/o Traveltime Car Rental Pvt. Ltd., Office No. 105, HSIIDC Building, Udyog Astral Court, B Wing, Near Vs. Vihar, Phase-V, Near Gaikwad Petrol Pump, Shankar Chowk, NH-8, Sanewadi, Aundh, Pune- Gurgaon. 411007. PAN No.AAJCS6704P (Appellant) (Respondent) : Appellant by : Sh. Suraj Bhan Nain, Ld. Adv &Sh. Mahfuzur Rehman, Ld. CA Respondent by : Sh. Rajesh Kumar, Ld. CIT…

Nordex India Private Limited (Formerly Known As Acciona Windpower India Private Limited), Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal filed by the assessee stands partly allowed as indicated hereinabove

ITA 265/BANG/2022[2017-18]Status: DisposedITAT Bangalore31 May 2023AY 2017-18

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(Tp)A No. 265/Bang/2022 Assessment Year : 2017-18 M/S. Nordex India Pvt. Ltd., (Formerly Known As Acciona The Deputy Windpower India Pvt. Ltd.), Commissioner Of Municipal No. 2, Old No. 4, Income Tax, Prestige Emerald, Circle – 3(1)(1), Madras Bank Road, Vs. Bangalore. Corporation Division No. 1, Bangalore – 560 001. Appellant Respondent : Shri Nageshwar Rao, Assessee By Advocate Revenue By : Shri D.K. Mishra, Cit (Dr) Date Of Hearing : 13-03-2023 Date Of Pronouncement : 31-05-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 16.02.2022 Passed By Nfac, For Assessment Year 2017-18 On Following Grounds Of Appeal:

For Respondent: Shri Nageshwar Rao

Section 143(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND MS. PADMAVATHY S, ACCOUNTANT MEMBER IT(TP)A No. 265/Bang/2022 Assessment Year : 2017-18 M/s. Nordex India Pvt. Ltd., (Formerly known as Acciona The Deputy Windpower India Pvt. Ltd.), Commissioner of Municipal No. 2, Old No. 4, Income Tax, Prestige Emerald, Circle – 3(1)(1), Madras Bank Road, Vs. Bangalore. Corporation Division No. 1, Bangalore – 560 001. APPELLANT RESPONDENT : Shri Nageshwar Rao, Assessee by Advocate Revenue by : Shri D.K. Mishra, CIT (DR) Date of Hearing : 13-03-2023 Date of Pronouncement : 3…

M/S. Computer Science Corporation India Pvt. Ltd., Chennai vs. Deputy Commissioner of Income Tax-Circle 2(1), Indore

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

ITA 319/IND/2018[2013-14]Status: DisposedITAT Indore10 Apr 2023AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri P.K. Mishra, CIT DR

Section 143(3)Section 144C(13)Section 144C(8)

…ing operations. The Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of Ramgreen Solutions (P.) Ltd ITA Nos.179/Ind/2016, 292/Ind/2017, 319/Ind/2018 & SA No.46/Ind/2021 A.Ys. 2011-12, 2012-13 & 2013-14 Page 10 of 29 vs. CIT: [2015] 377 ITR 533 (Delhi), wherein the Court has held that functional similarity is of utmost importance while accepting or rejecting a comparable company. The Ld. AR further submitted that there is no segmental details available for this comparable. The Ld. AR pointed out that Annual Report of the company for FY 2010- 11 does not disclose segment wise profitabili…

M/S. Computer Science Corporation India Pvt. Ltd., Chennai vs. The ACIT-Circle 2(1), Indore

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

ITA 292/IND/2017[2012-13]Status: DisposedITAT Indore10 Apr 2023AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri P.K. Mishra, CIT DR

Section 143(3)Section 144C(13)Section 144C(8)

M/S. Computer Sciences Corporation India Private Limited, Indore vs. The Asst. Commissioner of Income Tax-2(1), Indore

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

ITA 179/IND/2016[2011-12]Status: DisposedITAT Indore10 Apr 2023AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri P.K. Mishra, CIT DR

Section 143(3)Section 144C(13)Section 144C(8)

ACIT, Circle -5 (1), Hyderabad vs. Quislex Legal Services Private Limited, Hyderabad

In the result, appeal of the Revenue is allowed for statistical purposes

ITA 105/HYD/2022[2014-15]Status: DisposedITAT Hyderabad06 Mar 2023AY 2014-15

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year:2014-15 Dy. C. I.T Vs. Quislex Legal Services Circle 5(1) (P) Ltd, Hyderabad Hyderabad Pan:Aaacq1153H (Appellant) (Respondent) C.O No.10/Hyd/2022 (Arising Out Of Ita No. 105/Hyd/2022) Assessment Year:2014-15 Quislex Legal Services (P) Vs. Dy. C. I.T Ltd, Hyderabad Circle 5(1) Pan:Aaacq1153H Hyderabad (Appellant) (Respondent) Assessee By: Shri H. Srinivasulu, Advocate Revenue By: Shri Jeeval Lal Lavidiya, Cit(Dr) Date Of Hearing: 06/02/2023 Date Of Pronouncement: 06/03/2023 O R D E R Per Laliet Kumar, J.M This Appeal Filed By The Revenue Is Directed Against The Order Dated 07.01.2022 Of The Learned Cit (A)-10, Relating To A.Y.2014-15 & The C.O Is Filed By The Assessee For The A.Y 2014-15. Page 1 Of 19

For Appellant: Shri H. Srinivasulu, AdvocateFor Respondent: Shri Jeeval Lal Lavidiya, CIT(DR)

…ITA 105 and CO 10 of 2022 Quislex Legal Services P Ltd Hyderabad आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ B ‘ Bench, Hyderabad Before Shri R.K. Panda, Accountant Member AND Shri Laliet Kumar, Judicial Member Assessment Year:2014-15 Dy. C. I.T Vs. Quislex Legal Services Circle 5(1) (P) Ltd, Hyderabad Hyderabad PAN:AAACQ1153H (Appellant) (Respondent) C.O No.10/Hyd/2022 (Arising out of ITA No. 105/Hyd/2022) Assessment Year:2014-15 Quislex Legal Services (P) Vs. Dy. C. I.T Ltd, Hyderabad Circle 5(1) PAN:AAACQ1153H Hyderabad (Appellant) (Respondent) Assessee by: Shri H. Srin…

Belden India Private Limited, Gurgaon vs. DCIT, Circle 1(1), Gurgaon

In the result, the appeal of the assessee is allowed

ITA 424/DEL/2022[2017-18]Status: DisposedITAT Delhi03 Feb 2023AY 2017-18

Bench: Sh. C. N. Prasaddr. B. R. R. Kumarita No. 424/Del/2022 : Asstt. Year : 2017-18 Belden India Pvt. Ltd., Vs Dcit, Unit No. 233-236, 2Nd Floor, Spaze Circle-1(1), Edge, Tower-B, Sohna Road, Sector- Gurgaon 47, Gurgaon, Haryana-122002 (Appellant) (Respondent) Pan No. Aaccb9624Q Assessee By : Sh. Vishal Kalra, Adv. Revenue By : Sh. Rajesh Kumar, Cit Dr Date Of Hearing: 30.01.2023 Date Of Pronouncement: 03.02.2023

For Appellant: Sh. Vishal Kalra, AdvFor Respondent: Sh. Rajesh Kumar, CIT DR

Section 143(1)Section 143(3)Section 92CSection 92C(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I’, NEW DELHI Before Sh. C. N. Prasad, Judicial Member Dr. B. R. R. Kumar, Accountant Member ITA No. 424/Del/2022 : Asstt. Year : 2017-18 Belden India Pvt. Ltd., Vs DCIT, Unit No. 233-236, 2nd Floor, Spaze Circle-1(1), Edge, Tower-B, Sohna Road, Sector- Gurgaon 47, Gurgaon, Haryana-122002 (APPELLANT) (RESPONDENT) PAN No. AACCB9624Q Assessee by : Sh. Vishal Kalra, Adv. Revenue by : Sh. Rajesh Kumar, CIT DR Date of Hearing: 30.01.2023 Date of Pronouncement: 03.02.2023 ORDER Per Dr. B. R. R. Kumar, Accountant Member: The present appeal has been filed by the asses…

Global Logic India Limited, Delhi vs. DCIT Tpo-2(1)(1), Delhi

In the result the appeal of the assessee is allowed

ITA 370/DEL/2022[2017-18]Status: DisposedITAT Delhi23 Nov 2022AY 2017-18

Bench: Shri Shamim Yahya & Ms. Astha Chandraassessment Year: 2017-18

For Appellant: Shri Neeraj Jain, AdvocateFor Respondent: Shri Mahesh Shah, CIT(DR)

Section 143(3)Section 92C

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”: NEW DELHI BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER AND MS. ASTHA CHANDRA, JUDICIAL MEMBER Assessment Year: 2017-18 Global Logic India Limited, Vs. DCIT, TPO-2(1)(1) 207, Gupta Archade LSC Delhi. Plot No. 05, Mayur Vihar, Phase-1 Extension, Delhi 110 001 PAN AABCI2526F (Appellant) (Respondent) Assessee by: Shri Neeraj Jain, Advocate Mr. Abhishek Aggarwal, CA, Ms. Shubhangi Jain, CA Department by: Shri Mahesh Shah, CIT(DR) Date of Hearing: 16.06.2022 Date of 23.11.2022 pronouncement O R D E R PER ASTHA CHANDRA, JM: The appeal of the assessee arises out of the…

Weatherford Drilling & Production Services (India) Pvt. Ltd., Vadodara vs. The Asstt. Commissioner of Income Tax, Circel-2(1)(2), Vadodara

In the result, appeal of the assessee is allowed

ITA 77/AHD/2019[2008-09]Status: DisposedITAT Ahmedabad21 Nov 2022AY 2008-09

For Appellant: Shri Dhanesh Bafna, A.R. &For Respondent: Shri Atul Pandey, Sr. D.R

Section 143(3)Section 92C

…THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “D” BENCH Before: Ms. Annapurna Gupta, Accountant Member And Shri Siddhartha Nautiyal, Judicial Member Assessment Year 2008-09 Weatherford Drilling & The ACIT, Production Services Circle-2(1)(2), (India) Pvt. Ltd., Vs Vadodara Block No. 74, (Respondent) Mukutnagar, Sokhada Road, Manjusar, Ta Savli, Baroda-391775 PAN: AAACW4068M (Appellant) Assessee by: Shri Dhanesh Bafna, A.R. & Ms. Chandni Shah, A.R. Revenue by: Shri Atul Pandey, Sr. D.R. Date of hearing : 23-08-2022 Date of pronouncement : 21-11-2022 आदेश/ORDER PER : SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER:…

Global E-Business Operations Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-5(3)(2), Bangalore

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 174/BANG/2022[2017-18]Status: DisposedITAT Bangalore16 Nov 2022AY 2017-18

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri Harinder Kumar, D.R

Section 144(3)Section 37Section 92C

…that of assessee even though assessee before us also carries out certain services on contract basis. Ld. AR has placed reliance upon decision of Hon'ble Delhi High Court in case of Rampgreen Solutions (P.) Ltd. v. CIT [2015] 60 taxmann.com 355/234 Taxman 573/377 ITR 533 Hon'ble Court had held that once a company falls into the category of high-end KPO, it cannot be functionally comparable with a BPO service provider like that of assessee. Applying this reissue in the present case, we direct Ld.AO to eliminate this comparable from final list." 30. In view of the above order of the Tribunal, we are inclined to dir…

Ocwen Financial Solutions Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Special Range-5, Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 342/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Oct 2022AY 2016-17

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.342/Bang/2021 : Asst.Year 2016-2017 M/S.Ocwen Financial Solutions The Assistant Commissioner Private Limited Of Income-Tax V. Pritech Park, Survey No.51 To Special Range – 5 64/4, Block No.12, Unit 2, 5B & Bangalore. 6A Floors, Bellandur Village, Sarjapur Marathahalli Ring Road Bengaluru – 560 103. Pan : Aaaco3764E. (Appellant) (Respondent) Appellant By : Sri.Ankur Pai & Sri. K.R.Vasudevan, Advocates Respondent By : Sri.K.Sankar Ganesh, Jcit-Dr Date Of Pronouncement : 14.10.2022 Date Of Hearing : 13.10.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 30.03.2021 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2016-2017. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Engaged In Providing It Enabled Services To Ocwen Mortgage Servicing Inc. Usvi. The Assessee Is A Wholly Owned Subsidiary Of Ocwen Asia Holdings Limited, Mauritius. For The Assessment Year 2016-2017, The Return Of Income Was Filed On 29.11.2016 Declaring Total Income Of Rs.93,31,44,800. The Case Was Selected For Scrutiny

For Appellant: Sri.Ankur Pai & Sri. K.R.Vasudevan, AdvocatesFor Respondent: Sri.K.Sankar Ganesh, JCIT-DR

Section 143(2)Section 143(3)