Functional Dissimilarity between Companies and Assessee: Delhi HC upholds Order of ITAT Directing Exclusion of Comparables [Read Order]

The Delhi High Court upheld the order of the Income Tax Appellate Tribunal (ITAT) directing the exclusion of comparables as there was functional dissimilarity between the companies and the assessee. The record discloses that the respondent/assessee provides back-office support services i.e., call centre services to its Associated Enterprises (AEs). Besides this, the respondent/assessee also renders…