ITeS’ functionally not comparable to Knowledge Process Outsourcing

Future First Info Services Pvt. Ltd. Vs ACIT (ITAT Delhi) Issue- AO/DRP/TPO have erred in arbitrarily characterizing the Appellant as a High – end Knowledge Process Outsourcing (“KPO”) entity, relying on the Safe Harbour Rules. Ld. AR submitted that the functional profile of the assessee has been accepted by the TPO and no case was ever made out by the TPO that the assessee is a KPO. This is evident from Para 4 of TPO’s order (page 2) where the TPO has recorded “….The main international transactions of the assessee is the provisions of IT Enables services. The TP report has...