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

Bt E- Serv (India) Pvt. Ltd., New Delhi vs. ITO, New Delhi

In the result appeal No. 99/Del/2016 filed by the assessee for assessment year 2011 – 12 is partly allowed

ITA 565/DEL/2015[2010-11]Status: DisposedITAT Delhi30 Oct 2017AY 2010-11

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi & Bt E-Serv (India) Pvt. Ltd, Ito, 11Th Floor, Eros Corporate Tower, Ward-5(2), Vs. Nehru Place, New Delhi New Delhi Pan:Aadcb2533M (Appellant) (Respondent)

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri Amrandra Kumar, CIT DR

Section 10ASection 143Section 143(3)Section 144CSection 144C(3)Section 144C(5)Section 92C

…g different set of services such as data analytics, computer added simulations. It was further submitted that it is considered as a knowledge process outsourcing service provider as per Hon'ble Delhi High Court in Rampgreen Services Solutions Pvt. Ltd Vs. CIT 60 Taxmann.com 355. It was further submitted that it has exceptionally high margin and high turnover and further segmental data is also not available. In the end the ld AR relied upon the decision of Ameriprice India Pvt. Ltd Vs. ACIT 62 Taxmann.com 237. 37. The ld DR defended the order of the ld TPO as well as the ld DRP. 38. We have carefully considered th…

British Marine Plc-India Branch, Mumbai vs. DCIT (It) 1(3)(2)

In the result, the appeal is allowed for statistical purposes

ITA 1908/MUM/2016[2011-12]Status: DisposedITAT Mumbai27 Oct 2017AY 2011-12

Bench: Shri Mahavir Singh () & Shri N.K. Pradhan () Assessment Year: 2011-12 M/S British Marine Plc- Dcit(It)-1(3)(2) India Branch Mumbai. Vs. 903, ‘C’ Wing, 215, Antrium, Next To Courtyard, Marriot, A.K. Road, Andheri (E) Mumbai-400065 Pan No. Aaaco6627Q Appellant Respondent Assessee By : Shri Jiger Saiya & Shri Darshan Dalal, Ar Revenue By : Shri V. Jenardhenan, Dr Date Of Hearing : 31/07/2017 Date Of Pronouncement : 27/10/2017

For Appellant: Shri Jiger Saiya &For Respondent: Shri V. Jenardhenan, DR

Section 143(3)Section 144CSection 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “K” MUMBAI BEFORE SHRI MAHAVIR SINGH (JUDICIAL MEMBER) AND SHRI N.K. PRADHAN (ACCOUNTANT MEMBER) Assessment Year: 2011-12 M/s British Marine PLC- DCIT(IT)-1(3)(2) India Branch Mumbai. Vs. 903, ‘C’ Wing, 215, Antrium, Next to Courtyard, Marriot, A.K. Road, Andheri (E) Mumbai-400065 PAN No. AAACO6627Q Appellant Respondent Assessee by : Shri Jiger Saiya & Shri Darshan Dalal, AR Revenue by : Shri V. Jenardhenan, DR Date of Hearing : 31/07/2017 Date of pronouncement : 27/10/2017 ORDER PER N.K. PRADHAN, A.M. This is an appeal filed by the assessee. The relevant a…

Utstarcom Inc., New Delhi vs. DDIT, New Delhi

ITA 1829/DEL/2014[2009-10]Status: DisposedITAT Delhi25 Oct 2017AY 2009-10

Bench: Shri R.K. Panda & Shri Kuldip Singh

For Appellant: S/Shri Rajan Sachdev, Maneesh Bawa and Jitendra Singh, CAsFor Respondent: Shri H.K. Choudhary, CIT DR

Section 10ASection 143Section 144CSection 92D

…IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH ‘I-2’ : NEW DELHI) BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER and SHRI KULDIP SINGH, JUDICIAL MEMBER ITA No.1829/Del./2014 (ASSESSMENT YEAR : 2009-10) UT Starcom Inc., vs. DDIT, Circle 2 (2), 49, First Floor, LSC No.1, International Taxation, Plot No.13 & 14, DDA Market, New Delhi Sector 6, Dwarka, New Delhi – 110 075. (PAN : AAACU5017A) (APPELLANT) (RESPONDENT) ASSESSEE BY : S/Shri Rajan Sachdev, Maneesh Bawa and Jitendra Singh, CAs REVENUE BY : Shri H.K. Choudhary, CIT DR Date of Hearing : 11.09.2017 Date of Order : 25.10.2017 O R D E R PER KULDIP SINGH, JUDICI…

Ariba India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal is allowed for statistical purposes

ITA 5201/DEL/2012[2007-08]Status: DisposedITAT Delhi25 Sept 2017AY 2007-08

Bench: Shri R.S. Syal & Shri Sudhanshu Srivastavassessment Year : 2007-08

For Appellant: Shri Manoneet Dalal, Shri Ashu ChokhaniFor Respondent: Shri Amrender Kumar, CIT, DR &

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : I-1 : NEW DELHI BEFORE SHRI R.S. SYAL, VICE PRESIDENT AND SHRI SUDHANSHU SRIVASTAV, JUDICIAL MEMBER Assessment Year : 2007-08 Ariba India Pvt. Ltd., Vs. DCIT, Regus Business, Circle-12(1), 15th Floor, Eros Corporate Towers, New Delhi. Nehru Place, New Delhi. PAN: AAACF4192P (Appellant) (Respondent) Assessee By : Shri Manoneet Dalal, Shri Ashu Chokhani, CA & Shri Vishu Goel Department By : Shri Amrender Kumar, CIT, DR & Shri Kumar Pranav, Sr.DR Date of Hearing : 21.09.2017 Date of Pronouncement : 25.09.2017 ORDER PER R.S. SYAL, VP: This appeal filed by the…

The Pr. Commissioner of Income Tax-1 vs. New River Software Services Pvt. Ltd

The appeal is dismissed therefore on account of both delay as well

ITA/924/2016HC Delhi22 Aug 2017

Bench: The High Court Of Andhra Pradesh & Telangana. That Appeal Was Dismissed On The Ground Of Maintainability On 30Th June, 2016.

…ITA 924/2016 Page 1 of 4 $~9 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA No. 924/2016 THE PR. COMMISSIONER OF INCOME TAX-1 ..... Appellant Through: Mr. Ruchir Bhatia, Senior Standing Counsel for the Revenue. versus NEW RIVER SOFTWARE SERVICES PVT. LTD. ..... Respondent Through: Mr. Kamal Sawhney, Mr. Shikhar Garg & Mr. Prashant Meharchandani, Advocates. CORAM: JUSTICE S.MURALIDHAR JUSTICE PRATHIBA M. SINGH O R D E R % 22.08.2017 C.M. No. 30036/2017 (for condonation of 7 days’ delay in filing the reply) 1. The application has been fi…

American Express (India) Pvt. Ltd., New Delhi vs. DCIT, New Delhi

The appeal of the assessee is partly allowed

ITA 1868/DEL/2015[2007-08]Status: DisposedITAT Delhi06 Jul 2017AY 2007-08

Bench: Shri Amit Shukla & Shri Prashant Maharishiamerican Express (India) Pvt. Ltd, Vs. Dcit, Metropolitan Saket, 7Th Floor, Circle-2(2), Office Block, District Centre, New Delhi Saket, New Delhi Pan:Aaaca8163F (Appellant) (Respondent) Dcit, Vs. American Express (India) Pvt. Circle-2(2), Ltd, New Delhi Metropolitan Saket, 7Th Floor, Office Block, District Centre, Saket, New Delhi Pan: Aaaca8163F (Appellant) (Respondent)

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri TM Shivakumar, CIT DR

Section 10Section 143Section 143(3)Section 144CSection 92C

…the same work. He further referred that data analysis is the main function of this comparable which is also done by the assessee. Hence, he pressed for retaining the same. 43. We have carefully considered the rival contentions. The Hon'ble Delhi High Court in 377 ITR 533 in Rampgreen solutions Pvt. Ltd Vs. CIT, has specifically held that this comparable company is engaged in KPO services. Further, the special bench in case of Mersk Global Centre India Pvt. Ltd Vs. ACIT 147 ITD 83 has also held that the comparable is KPO and excluded this company. Therefore, respectfully following the decision of the Hon'ble Delhi…

Evalueserve Sez (Gurgaon) Pvt. Ltd., Gurgaon vs. ACIT, New Delhi

In the result, the appeal of the assessee is partly allowed with above direction

ITA 1467/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Jun 2017AY 2010-11

Bench: Bhavnesh Saini & Shri Prashant Maharishievalueserve Sez (Gurgaon) Vs. Assistant Commissioner Of Private Ltd, Income Tax, Circle-8(2), 8Th, 9Th & 10Th Floor, Building New Delhi No. 04, Unitech Realty Projects Ltd, Sez, Tikri, Sector-48, Gurgaon Harya-122002 Pan:Aabce8812A (Appellant) (Respondent)

For Appellant: Ms. Ananya Kapoor, AdvFor Respondent: Shri. Amrendra Kumar, CIT DR

Section 143(3)Section 144CSection 144C(5)Section 92Section 92CSection 92D

…757, 758)- it is a KPO td.(pg. 734- 7014/Del/2014)(pg. 69-70 2) Unreliable data- the standalone 37- Vol. 3- of CLC) Annual financials include the turnover 2) Rampgreen Solutions vs. Report) of the subsidiaries also (pg. CIT (ITA No. 102/2015)- 784, 808, 827) 377 ITR 533 (Del) 3) Significant intangible assets.- (computer software- pg. 787) ' 4) Insufficient Segmental details Igate global 1) Delhi High Court- PCIT solutions vs. Ameriprise India P. 3 td.(pg. 838- 1. Exceptional year of operations Ltd.- ITA No. 461/16- pg. 42- Vol. 3- (amalgamation) (pg. 888k hence 79A- 79B CLC mnual veport) 2) United HealthGroup fa…

Mckinsey Knowledge Centre India Pvt. Ltd., Gurgaon vs. DCIT, New Delhi

In the result ground No. 14 of the appeal of the assessee is dismissed

ITA 6648/DEL/2016[2012-13]Status: DisposedITAT Delhi11 May 2017AY 2012-13

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishimckinsey Knowledge Centre India Pvt. Vs. Dcit, Ltd, Circle-16(2) 3Rd Floor, Block-Iii, Vatika Business Park, New Delhi Sector-49, Sohna Road, Gurgaon Pan:Aaccm2356G (Appellant) (Respondent)

For Appellant: Shri Porus KakaFor Respondent: Shri Amrendra Kumar, CIT DR

Section 143(3)Section 143(3)(ii)Section 144CSection 92C

…itted that even in case of TNMM, standard of comparability for application is not less than application of any other transfer pricing method. He further referred to decision of Hon‟ble Delhi High Court in case of Rampgreen solutions (P) Ltd versus CIT (Delhi) 377 ITR 533 and submitted that even in case of TNMM comparability analysis for identifying comparables cannot be different then other transfer pricing methods. Hence, McKinsey Knowledge Centre India Pvt. Ltd V DCIT 6648/Del/2016 A Y 2012-13 according to him dehors whatever is held by the courts, for transfer pricing analysis comparables should be selected…

Sh. Evalueserve.Com Private Ltd., New Delhi vs. ITO, New Delhi

In the result ground No. 8 of the appeal of the assessee is dismissed

ITA 4001/DEL/2013[2006-07]Status: DisposedITAT Delhi11 May 2017AY 2006-07

Bench: Shri I. C. Sudhir & Shri Prashant Maharishievalueserve.Com Private Vs. Ito, Ltd, Ward-11(2), 701, Guru Apartments, New Delhi Sector-14, Rohni, New Delhi Pan: Aaace8014F (Appellant) (Respondent)

For Appellant: i. Sh. Salil Kapoor, Adv ii. Sh. Sumit Lal ChandaniFor Respondent: Sh. Neeraj Kumar, Sr. DR

Section 10ASection 143(3)(ii)Section 234BSection 271Section 92Section 92C

…n that assessee is engaged in low end service/BackOffice enabled ITES support services and hence cannot be compared to a knowledge process outsourcing unit. He further referred to the decision of the Hon‘ble Delhi High Court in case of Rampgreen solutions Ltd 377 ITR 533 wherein it has been stated that Vishal information technologies Ltd is a KPO and has discussed this comparable in detail and stated that it cannot be compared to companies engaged in low and services/BackOffice enabled ITES support services. He further referred to the plethora of decisions wherein this comparable company has held to be engaged in…

M/S Travel Security Services (India) Pvt. Ltd., New Delhi vs. DCIT, New Delhi

ITA 6828/DEL/2015[2011-12]Status: DisposedITAT Delhi12 Apr 2017AY 2011-12

Bench: Shri R.S. Syal & Ms Suchitra Kambleassessment Year : 2011-12 Travel Security Services (India) Pvt. Ltd., Vs. Dcit, Suit No.603-04, 6Th Floor, Circle 25(2), Copia Corporation Suites, New Delhi. Plot No.9, Jasola District Centre, New Delhi. Pan: Aacct9754B (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate, Shri Neeraj Jain, Advocate & Ms Deepika Agarwal, Ca Department By : Shri Neeraj Kumar, Sr.Dr

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Neeraj Kumar, Sr.DR

Section 143(3)Section 144C

…o requirement to have identical services for the purpose of making comparison under the TNMM. 12. We are unable to accept this argument in view of the judgment of the Hon'ble jurisdictional High Court in the case of Rampgreen Sales Pvt. Ltd. vs. CIT (2015) 377 ITR 533 (Del) in which it has been held that the comparables are to be selected on the basis of similarity even under TNMM. The Hon'ble High Court has laid down that selection of comparables does not differ with the method adopted. Ex consequenti, it is no more open to argue that the functional dissimilarity of the companies under the overall broader cat…

Willis Processing Services (India) P.Ltd, Mumbai vs. Asst CIT (OSD) 2(3), Mumbai

ITA 6877/MUM/2012[2008-09]Status: DisposedITAT Mumbai22 Mar 2017AY 2008-09

Bench: Shri G.S. Pannu, Am & Shri Ravish Sood, Jm आयकर अपील सं./ I.T.A. No. 6877/Mum/2012 (निर्धारण वर्ा / Assessment Year: 2008-09)

For Appellant: Sh. R.R Vora and Nikhil TiwariFor Respondent: Sh. Debashis Chanda

Section 133Section 143(3)Section 144CSection 92C(3)Section 92C(4)

…n the case of the aforesaid comparable, viz Coral Hub the same stood reflected at 4.40%. That it was on account of the said substantially low personnel cost that the Hon’ble High Court of Delhi had in the case of : Rampgreen Solutions Pvt. Ltd. Vs. CIT (2015) 377 ITR 533 (Del), therein observing that as the expenditure on employment cost during the relevant period of the aforesaid comparable was a small fraction of the proportionate cost incurred by the assessee, for the reason that most of its work was outsourced to other vendors/service providers, had thus concluded that the same in itself proved that the afore…

Abercrombie & Kent India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal is partly allowed

ITA 5742/DEL/2011[2007-08]Status: DisposedITAT Delhi09 Mar 2017AY 2007-08

Bench: Shri I. C. Sudhira N D Shri Prashant Maharishi

For Appellant: Shri P. C. Yadav, AdvFor Respondent: Shri Amrendra Kumar, CIT [DR]

…view of the above facts and figures it can be said that the functions performed by the assessee and C&K are entirely different and nature of income is also different. Recently Hon’ble Delhi high court in the case of Rampgreen Solutions ltd Vs CIT reported in 377 ITR 533(Del) has held that though entities rendering voice call services and a KPO service provider employs IT based delivery system but the charterstics of services, functional aspects, business envoirnment risk and quality of human resources employed are materially different and hence cannot be compared with each other. Risk Risk undertaken by assess…

Abercrombie & Kent India Pvt. Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal is partly allowed

ITA 4229/DEL/2010[2006-07]Status: DisposedITAT Delhi09 Mar 2017AY 2006-07

Bench: Shri I. C. Sudhira N D Shri Prashant Maharishi

For Appellant: Shri P. C. Yadav, AdvFor Respondent: Shri Amrendra Kumar, CIT [DR]

Pangea3 Legal Database Systems P.Ld, Mumbai vs. ITO WD 3(2)(4), Mumbai

In the result, the appeal of the assessee is partly allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

ITA 2128/MUM/2014[2009-10]Status: DisposedITAT Mumbai06 Mar 2017AY 2009-10

Bench: Shri Amit Shukla & Shri Manoj Kumar Aggarwalassessment Year: 2009-10

For Appellant: Shri Rajan Vora, &For Respondent: Mrs. Malathi Shridharan, CIT DR

Section 143(3)Section 144C(5)

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “K”, MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI MANOJ KUMAR AGGARWAL, ACCOUNTANT MEMBER Assessment Year: 2009-10 Pangea3 & Legal Income Tax Officer, Ward- Database Systems Pvt. 3(2)(4), Room No.673, 6th Ltd., 102-B, Leela floor, Aayakar Bhavan, M.K. Vs. Business Park, Andheri Marg, Mumbai-400020 Kurla Road, Andheri (East), Mumbai-400 060 PAN: AADCP8581H) (Appellant) (Respondent) & Assessment Year: 2009-10 Income Tax Officer, Pangea3 & Legal Database Ward-3(2)(4), Room Systems Pvt. Ltd. No.673, 6th floor, 102-B, Leela Business Vs. Aayakar Bhavan,…

ITO 3(2)(4), Mumbai vs. Pangea 3 Legal Data Base Systems P.Ltd, Mumbai

In the result, the appeal of the assessee is partly allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

ITA 1958/MUM/2014[2009-10]Status: DisposedITAT Mumbai06 Mar 2017AY 2009-10

Bench: Shri Amit Shukla & Shri Manoj Kumar Aggarwalassessment Year: 2009-10

For Appellant: Shri Rajan Vora, &For Respondent: Mrs. Malathi Shridharan, CIT DR

Section 143(3)Section 144C(5)

Tevapharm India Pvt. Ltd., New Delhi vs. Addl. CIT, New Delhi

In the result, the appeal is partly allowed

ITA 6707/DEL/2016[2012-13]Status: DisposedITAT Delhi06 Mar 2017AY 2012-13

Bench: Shri R.S. Syal & Shri Kuldip Singhassessment Year : 2012-13 Tevapharm India Pvt. Ltd., Vs. Addl. Cit, M-34, Saket, Special Range-9, New Delhi. New Delhi. Pan: Aabcr7561F (Appellant) (Respondent) Assessee By : Shri Himanshu S. Sinha, Advocate & Ms Vrinda Tulshan, Advocate Department By : Shri Peeyush Jain, Cit, Dr

For Appellant: Shri Himanshu S. Sinha, Advocate &For Respondent: Shri Peeyush Jain, CIT, DR

Section 143(3)Section 144C(13)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : I-2 : NEW DELHI BEFORE SHRI R.S. SYAL, ACCOUNTANT MEMBER AND SHRI KULDIP SINGH, JUDICIAL MEMBER Assessment Year : 2012-13 Tevapharm India Pvt. Ltd., Vs. Addl. CIT, M-34, Saket, Special Range-9, New Delhi. New Delhi. PAN: AABCR7561F (Appellant) (Respondent) Assessee By : Shri Himanshu S. Sinha, Advocate & Ms Vrinda Tulshan, Advocate Department By : Shri Peeyush Jain, CIT, DR Date of Hearing : 02.03.2017 Date of Pronouncement : 06.03.2017 ORDER PER R.S. SYAL, AM: This appeal by the assessee is directed against the final assessment order dated 30.11.2016 passe…

M/S. Mps Technologies Ltd., Chennai vs. ACIT, Chennai

In the result, appeal of the assessee is partly allowed for 20

ITA 2031/CHNY/2011[2007-08]Status: DisposedITAT Chennai14 Feb 2017AY 2007-08

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A.No. 2031/Mds/2011 "नधा"रण वष" /Assessment Year : 2007-2008. M/S. Mps Technologies Ltd, Vs. The Assistant Commissioner (Since Merged With Mps Ltd) Of Income Tax, 27, G.N. Chetty Road, Company Circle Iv(3) T. Nagar, Chennai. Chennai 600 017. [Pan Aaecm 0205A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri. Vikram Vijayaraghavan, AdvFor Respondent: Shri. Pathclavath Peereja, CIT

Section 144C

…. As per ld. Authorised Representative, assessee being only a low level BPO, could not be compared with Ecelrx Services Ltd. For :- 4 -: this reliance was placed on the judgment of Hon’ble Delhi High Court in the case of Ramp Green Solutions P. Ltd vs. CIT 377 ITR 533. 4. Viz-a-viz Infosys BPO Limited, ld. Authorised Representative submitted that it had a turnover of "650 crores. As per ld. Authorised Representative assessee’s turnover was only "33.5 crores. Relying on the judgment of Hon’ble Bombay High Court in the case of CIT vs. M/s. Pentair Water India Pvt. Ltd, (2016) 381 ITR 216 and that of Hon’ble D…

DCIT (Ltu), New Delhi vs. M/S. Exl Service.Com (India) Pvt. Ltd., New Delhi

In the result, the appeal by the assessee as well as ofthe department are partly allowed for statistical purposes

ITA 615/DEL/2015[2010-11]Status: DisposedITAT Delhi03 Jan 2017AY 2010-11

Bench: Sh. N. K. Saini, Am & Sh. Kuldip Singh, Jm Ita No. 302/Del/2015 : Asstt. Year : 2010-11 Exl Service.Com (India) Pvt. Ltd., Vs Deputy Commissioner Of Income 414, 4Th Floor, Dlf Jasola, Tax, Large Tax Payer Unit, Tower-B, Plot No. 10 & 11, Dda New Delhi District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Ita No. 615/Del/2015 : Asstt. Year : 2010-11 Deputy Commissioner Of Income Vs Exl Service.Com (India) Pvt. Ltd., 414, 4Th Floor, Dlf Jasola, Tower- Tax, Circle-1 (Ltu), New Delhi-110017 B, Plot No. 10 & 11, Dda District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Pan No. Aaace5174C Assessee By : Sh. Ajay Vohra, Adv. Sh. Abhishek Agarwal, Adv. Revenue By : Sh. Piyush Jain, Cit Dr Date Of Hearing : 07.10.2017 Date Of Pronouncement : 03.01.2017 Order Per N. K. Saini, Am:

For Appellant: Sh. Ajay Vohra, AdvFor Respondent: Sh. Piyush Jain, CIT DR

Section 143(3)Section 92D

…tual 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 533/234 Taxman 573/60 taxmann.com 355 (Delhi) wherein 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…

Exl Service.Com (India) Pvt. Ltd., New Delhi vs. DCIT (Ltu), New Delhi

In the result, the appeal by the assessee as well as ofthe department are partly allowed for statistical purposes

ITA 302/DEL/2015[2010-11]Status: DisposedITAT Delhi03 Jan 2017AY 2010-11

For Appellant: Sh. Ajay Vohra, AdvFor Respondent: Sh. Piyush Jain, CIT DR

Section 143(3)Section 92D

Hinduja Global Solutions Ltd ( Formerly Known As Htmt Global Solutions Ltd), Mumbai vs. DCIT 8(2), Mumbai

In the result, assessee’s appeal is partly allowed and Revenue’s appeal is dismissed

ITA 4933/MUM/2012[2007-08]Status: DisposedITAT Mumbai16 Dec 2016AY 2007-08

Bench: Shri Rajendra & Shri Saktijit Deyआयकर अपीऱ सं. / Ita No. 4933/Mum./2012 (निर्धारण वषा / Assessment Year : 2007–08) Hinduja Global Solutions Limited (Formerly Known As Htmt Global Solutions Ltd.) 171, Hinduja House ……………. Appellant Dr. Annie Besant Road, Worli Mumbai 400 018 Pan – Aaact1763A V/S Dy. Commissioner Of Income Tax ……………. Respondent Circle–8(2), Mumbai आयकर अपीऱ सं. / Ita No. 4950/Mum./2012 (निर्धारण वषा / Assessment Year : 2007–08) Dy. Commissioner Of Income Tax ……………. Appellant Circle–8(2), Mumbai V/S Hinduja Global Solutions Limited (Formerly Known As Htmt Global Solutions Ltd.) 171, Hinduja House ……………. Respondent Dr. Annie Besant Road, Worli Mumbai 400 018 Pan – Aaact1763A निर्धाररती की ओर से / Assessee By : Shri Batik Poddar A/W Ms. Karishma Phatarphekar & Shri Harsh Shah रधजस्व की ओर से / Revenue By : Shri N.K. Chand सुिवधई की तधरीख / आदेश घोषणध की तधरीख / Date Of Hearing – 05.10.2016 Date Of Order – 16.12.2016

For Appellant: Shri Batik Poddar a/wFor Respondent: Shri N.K. Chand

Section 10A

…ing (KPO), hence, cannot be compared to low end 8 Hinduja Global Solutions Limited BPO service provider. In support of such contention, learned Authorised Representative relied upon the following decisions:– i) Rampgreen Solutions Pvt. Ltd. v/s CIT, [2015] 377 ITR 533 (Del.); ii) ITO v/s Knoah Solutions P. Ltd., ITA no.1407/Hyd./2013, order dated 25th April 2014; iii) C3i Support Services Pvt. Ltd., v/s ACIT, [2014] 151 ITD 348 (Hyd.); and iv) iQor India Services Pvt. Ltd. v/s ITO, [2015] 57 taxmann.com 416 (Del. Trib.). 12. Learned Departmental Representative relied upon the observations of the Assessing Off…