Court held that\u00a0 the Tribunal had followed the procedures laid down in rule\u00a010B(2)(a). The Tribunal had found that the three comparables were providing services which were different from the assessee. A was rendering knowledge process outsourcing services. The Tribunal had said that it was engaged in medical transcription services, which compendiously had been given the name electronic medical record. Likewise, in so far as the BNR was concerned, the Tribunal once again returned the finding of fact that it was engaged in providing medical transcription services. Similarly, in so far as IT was concerned, the Tribunal noted that it provided financial research and data management services. More particularly, in so far as IT was concerned, the Tribunal noted that it was a leading player in knowledge process outsourcing services, which extended from financial content to financial industry. The order of the Tribunal was based on facts. No question of law arose from the order.(AY.2012-13)<\/p>\n","protected":false},"excerpt":{"rendered":"
S. 92CA : Transfer pricing-Reference to Transfer Pricing Officer-Arm\u2019s Length price-Avoidance of tax-Transactions with Associated Enterprises-Arm\u2019s length price-Question of fact-No substantial question of law.[S.92C, 260A, R.10B(2)(a)]<\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[21],"tags":[],"class_list":["post-45801","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-bUJ","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/45801","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=45801"}],"version-history":[{"count":1,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/45801\/revisions"}],"predecessor-version":[{"id":45802,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/45801\/revisions\/45802"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=45801"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=45801"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=45801"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}