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TMI Blog2021 (12) TMI 1474X X X X Extracts X X X X X X X X Extracts X X X X ..... h price (ALP) adjustment - HELD THAT:- We note at the outset that this tribunal s co-ordinate bench order in Assessment Year 2009-10 in assessee's case [ 2014 (11) TMI 129 - ITAT HYDERABAD] itself has already excluded M/s. Eclerx Services Ltd., M/s. Cosmic Global Limited and Infosys BPO on the ground that they provide KPO services, have different business model(s) since having huge sub-contr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hich is also found to be catering mainly to M/s. Citi Group having diversified portfolio than assessee's IT Enabled Services segment. Suffice to say, the learned panel has taken due note of all applicable judicial precedents as well. We thus decline the Revenue s instant sole substantive grievance as well as the main appeal. - SHRI S.S. GODARA, JUDICIAL MEMBER AND SHRI L. P. SAHU, ACCOUNTA ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... arm s length price (ALP) adjustment of Rs.4,64,59,132; we note that the corresponding directions under challenge to this effect read as under: 3. Learned department representative vehemently contended during the course of hearing the DRP s directions have erred in law and on facts in rejecting the foregoing eight entities namely (i) M/s. Acropetal Technologies Ltd. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... self has already excluded M/s. Eclerx Services Ltd., M/s. Cosmic Global Limited and Infosys BPO on the ground that they provide KPO services, have different business model(s) since having huge sub-contracting company brand value, diversified activity and other functional dissimilarities; respectively. The Revenue has admittedly not indicated any distinction for the relevant facts in these twin ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... all applicable judicial precedents (supra) as well. We thus decline the Revenue s instant sole substantive grievance as well as the main appeal ITA 423/Hyd/2016. 7. Learned authorized representative invited our attention to the assessee's C.O. No.25/Hyd/2016 that the same stands rendered infructuous in view of our foregoing detailed discussion declining the Revenue s appeal. Rejected accord ..... X X X X Extracts X X X X X X X X Extracts X X X X
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