Mumbai ITAT upholds per hour billing rate published by NASSCOM for a specific business segment as an external CUP in determining the arm’s length price

Advertisement Facts:- The Mumbai bench of the Income Tax Appellate Tribunal (ITAT) has recently pronounced its ruling on an appeal originating from a transfer pricing adjustment imposed on 3 Global Services Private Limited (“assessee”). The assessee operates in the voice based customer care segment within the IT-enabled services (ITeS) industry. During financial year 2003-04, the assessee rendered services to its associated enterprises (“AEs”). The Comparable Uncontrolled Price (CUP) method was selected as the most appropriate method to justify the arm’s length result of transact...