BPO / KPO Companies – Companies in ITES cannot be classified into low-end BPO services and high-end KPO services for TP comparability analysis

This Special Bench has been constituted by the Hon’ble President to dispose of the appeal filed by the assessee against the order passed by the ld. ACIT- Circle -6(3), Mumbai (A.O.) u/s 143(3) of the Income Tax  Act, 1961 in pursuance of the directions given by the Dispute Resolution Panel – I (DRP) u/s 144-C-(5) of the Income tax Act, 1961 and specifically to decide the following important questions (as reframed) involved therein:- “1) Whether for the purpose of determining arm’s length price of international transactions of the assessee-company, providing back office...