Court held that the activities of assessee-company comprises of BPO (business process outsourcing) services and the comparable company is engaged in the activities such as payroll activity, KPO (knowledge process outsourcing) services, development of products and IT services and not BPO services, hence such company cannot be accepted as comparable (ITA. No .1226 of 2015 dt. 23-04-2018)(AY. 2009-2010)
PCIT .v. BNY Mellon International Operations (India) (P.) Ltd (2018) 255 Taxman 397 (Bom)(HC)
S. 92C : Transfer pricing – Arms’ length price -company engaged in providing BPO services – Comparable company engaged in KPO and other IT services hence cannot be accepted as valid comparable