Comparable transactions/entity must be selected based on similarity with controlled transaction/entity

Brief of the Case: In the  case of Rampgreen Solutions Pvt Ltd vs CIT, Delhi High Court inter-alia held that the expression ‘BPO’ and ‘KPO’ are, plainly, understood in the sense that whereas, BPO does not necessarily involve advanced skills and knowledge; KPO, on the other hand, would involve employment of advanced skills and knowledge for providing services. Thus, the expression ‘KPO’ in common parlance is used to indicate an ITeS provider providing a completely different nature of service than any other BPO service provider. A KPO service provider would also be functionally diff...