TP- Comparability of High End Cos with Low End Cos in ITES/ BPO Sector

Vodafone India Services P. Ltd. Vs. DCIT (ITAT Mumbai), ITA No.7140 /Mum/2012, Date of Pronouncement: 26/4/2013 The dispute is regarding selection of comparables for bench marking the international transaction entered into by the assessee. The assessee had selected 9 comparables as unrelated parties for comparing the transaction in case of the assessee. The AO further selected 23 more comparables out of which 2 comparables i.e. Spanco and Flextronics (Seg.) were accepted by the assessee as comparable and the 21 comparables were disputed by the assessee. Out of these 21 cases, CIT (A) has accep...