Dy. CIT v. Morgan Stanley Advantage Services P. Ltd. (2019) 74 ITR 456 (Mum.)(Trib.)

S. 92C : Transfer pricing-Arms’ length price-International transactions- Benchmarking of transactions-Comparable-Back office support services-Company providing consultancy business solution and testing and high end business process outsourcing services-Cannot be held to be comparables.

Assessee providing back office support services,.  company providing high end data analytics and customised process solution and leading Indian provider of knowledge process outsource services functionally different.  High end diversified services. Company having income from translation charges. company having lower employee cost to sales than assessee.   company having different financial year ending.   Company under serious indictment in fraud cases. Company providing consultancy business solution and testing and high end business process outsourcing services  is held to be  not comparables.  (AY.  2007-08).