Concern with extraordinary event cannot be comparable in year of amalgamation

American Express Services India Private Ltd. Vs DCIT (ITAT Delhi) The assessee is aggrieved by the inclusion of the Accentia Technologies Ltd. in the final set of comparables. The plea of the assessee before us is that the said concern is engaged in diversified services which includes HRCM (using SaaS model), also is KPO and not BPO. Further it owns significant intangible assets to the extent of 67%. Another aspect pointed out was that during the year, there was extra-ordinary activity of amalgamation. The assessee also pointed out that the TPO had included the said concern on the ground that ...