Serco BPO (P.) Ltd. v. DCIT (2021) 188 ITD 19 (Delhi)(Trib.)

S. 92C : Transfer pricing-Arm’s length price-Factors to be considered while accepting comparables-Web enabled customer care services, BPO services-Health care BPO services-Revenue filter-Held to be not comparable-Turnover of comparable company was 509 times-Not comparable-High Brand value-Not comparable.

A company, engaged in providing health care BPO services, was to be accepted as valid comparable where the assessee company was engaged in providing web enabled customer care services, BPO services, call centre services and I.T. enabled services. Company had not passed revenue filter adopted by TPO as its revenue had decreased from previous year due to decline in sales. This company could not be accepted as valid comparable. The turnover of assessee was Rs. 1.83 crores and comparable had a turnover of Rs. 932 crores which was 509 times more than that of assessee. Not accepted as comparable.Company having huge turnover and high brand value as compared to assessee could not be accepted as valid comparable. (AY. 2010-11)