THE ITAT
President is learnt to have constituted a Special Bench in the case of
M/s Maersk Global Service Centres India Pvt Ltd. The Bench will comprise
of Vice President D Manmohan, I P Bansal and P M Jagtap. The two
questions which have been referred to the Bench are as follows:
1. "Whether for the purpose of conducting FAR analysis for determining
the arm's length price of international transactions of Indian companies
providing low end back office support services to their overseas
associated enterprises, companies performing high-end services (KPO)
should be considered as comparable?".
2. "Whether companies earning abnormally high profit margins should be
included in the list of comparable cases for the purpose of determining
the arm's length price of an international transaction?"
The Appeal is listed for hearing on 06.01.2014 at
Mumbai.
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