KPO Service Provider Not Comparable to ITES for Transfer Pricing Benchmarking

PCIT Vs SBI Business Process Management Services Pvt. Ltd. (Delhi High Court) In the case of Principal Commissioner of Income Tax (PCIT) vs. SBI Business Process Management Services Pvt. Ltd., the Delhi High Court addressed significant issues regarding the comparability of service providers for transfer pricing purposes. The core dispute revolved around whether certain Knowledge Process Outsourcing (KPO) service providers could be considered comparable to IT Enabled Services (ITES) providers for the purpose of benchmarking international transactions. The Income Tax Appellate Tribunal (ITAT) ha...