w w w . L a w y e r S e r v i c e s . i n



Swiss Re Global Business Solutions India Private Limited v/s Assistant Commissioner of Income Tax


Company & Directors' Information:- B N GLOBAL PRIVATE LIMITED [Active] CIN = U15400PB2014PTC038543

Company & Directors' Information:- E 2 E SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200DL2000PTC107313

Company & Directors' Information:- K V GLOBAL PRIVATE LIMITED [Active] CIN = U24100DL2014PTC263567

Company & Directors' Information:- GLOBAL CORPORATION LIMITED [Active] CIN = L74999DL1992PLC048880

Company & Directors' Information:- E-SOLUTIONS PRIVATE LIMITED [Active] CIN = U30007TN1999PTC043325

Company & Directors' Information:- T & I GLOBAL LTD. [Active] CIN = L29130WB1991PLC050797

Company & Directors' Information:- J. H. BUSINESS (INDIA) LIMITED [Amalgamated] CIN = U24293DL1999PLC099782

Company & Directors' Information:- D S R SOLUTIONS LIMITED [Active] CIN = U72200TG1999PLC032008

Company & Directors' Information:- K G GLOBAL PRIVATE LIMITED [Active] CIN = U74999DL2000PTC104788

Company & Directors' Information:- A. V. GLOBAL CORPORATION PRIVATE LIMITED [Active] CIN = U63090DL2007PTC159315

Company & Directors' Information:- J. K. SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999MH2014PTC257168

Company & Directors' Information:- GLOBAL BUSINESS SOLUTIONS LIMITED [Active] CIN = U22100KA2005PLC036141

Company & Directors' Information:- GLOBAL SOLUTIONS PRIVATE LIMITED [Active] CIN = U74899DL1988PTC031541

Company & Directors' Information:- GLOBAL BUSINESS INDIA PRIVATE LIMITED [Amalgamated] CIN = U16008DL1999PTC100758

Company & Directors' Information:- E-3 SOLUTIONS INDIA PRIVATE LIMITED [Active] CIN = U74910DL1998PTC096512

Company & Directors' Information:- A N GLOBAL LIMITED [Active] CIN = U92110MH1985PLC035269

Company & Directors' Information:- D S GLOBAL PRIVATE LIMITED [Active] CIN = U74899DL1995PTC071516

Company & Directors' Information:- G B BUSINESS LIMITED [Active] CIN = U51109WB1983PLC036744

Company & Directors' Information:- A B C GLOBAL PRIVATE LIMITED [Active] CIN = U51909PB2011PTC035103

Company & Directors' Information:- V A SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200TG2006PTC049266

Company & Directors' Information:- D P SOLUTIONS (INDIA) PRIVATE LIMITED [Strike Off] CIN = U22221DL2000PTC107837

Company & Directors' Information:- R P BUSINESS PRIVATE LIMITED [Active] CIN = U74210AS2000PTC006302

Company & Directors' Information:- A. S. INDIA LIMITED [Active] CIN = U70100MP2009PLC022300

Company & Directors' Information:- S N M BUSINESS PRIVATE LIMITED [Active] CIN = U51109WB1997PTC085308

Company & Directors' Information:- P R S BUSINESS PVT LTD [Active] CIN = U63090WB1992PTC056995

Company & Directors' Information:- N Q SOLUTIONS INDIA PRIVATE LIMITED [Active] CIN = U51909OR2009PTC011136

Company & Directors' Information:- I A T GLOBAL COMPANY PRIVATE LIMITED [Active] CIN = U24116DL1997PTC084916

Company & Directors' Information:- J D GLOBAL PRIVATE LIMITED [Active] CIN = U51909DL1997PTC091270

Company & Directors' Information:- IN-SOLUTIONS GLOBAL LIMITED [Active] CIN = U72200MH2004PLC146704

Company & Directors' Information:- IN-SOLUTIONS GLOBAL PRIVATE LIMITED [Active] CIN = U72200MH2004PTC146704

Company & Directors' Information:- M L B BUSINESS PRIVATE LIMITED [Active] CIN = U51109WB2000PTC091878

Company & Directors' Information:- GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U72900KA1997PTC022166

Company & Directors' Information:- J F C BUSINESS LTD [Active] CIN = U17125WB1990PLC048495

Company & Directors' Information:- B N G GLOBAL INDIA LIMITED [Active] CIN = U52590DL2011PLC225377

Company & Directors' Information:- A TO Z BUSINESS (INDIA) PRIVATE LIMITED [Under Process of Striking Off] CIN = U51909TZ2008PTC014261

Company & Directors' Information:- N K COMPANY (GLOBAL) PRIVATE LIMITED [Active] CIN = U52390WB2010PTC153624

Company & Directors' Information:- K B K GLOBAL PRIVATE LIMITED [Active] CIN = U24296DL2016PTC290487

Company & Directors' Information:- I. S. SOLUTIONS PRIVATE LIMITED [Active] CIN = U30007TG1997PTC028047

Company & Directors' Information:- GLOBAL E-SOLUTIONS LIMITED [Strike Off] CIN = U45201TN1994PLC028155

Company & Directors' Information:- S V BUSINESS PVT LTD [Active] CIN = U27310WB1984PTC038146

Company & Directors' Information:- R R BUSINESS PRIVATE LIMITED [Active] CIN = U74999WB2007PTC176588

Company & Directors' Information:- L T SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200TG2000PTC033248

Company & Directors' Information:- M R BUSINESS PRIVATE LIMITED [Active] CIN = U51109WB1994PTC064165

Company & Directors' Information:- M & D GLOBAL PRIVATE LIMITED [Active] CIN = U31101UP1974PTC003937

Company & Directors' Information:- J C BUSINESS PRIVATE LIMITED [Active] CIN = U55101AS2009PTC008974

Company & Directors' Information:- V R GLOBAL PRIVATE LIMITED [Active] CIN = U45200WB2007PTC120797

Company & Directors' Information:- D & B BUSINESS PRIVATE LIMITED [Active] CIN = U51909PB2010PTC033901

Company & Directors' Information:- L D SOLUTIONS PRIVATE LIMITED [Active] CIN = U51109DL2015PTC286921

Company & Directors' Information:- THE INDIA COMPANY PRIVATE LIMITED [Active] CIN = U74999TN1919PTC000911

Company & Directors' Information:- A S SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140DL2010PTC202208

Company & Directors' Information:- M M GLOBAL PRIVATE LIMITED [Strike Off] CIN = U29120WB1986PTC041280

Company & Directors' Information:- R V GLOBAL PRIVATE LIMITED [Active] CIN = U74990MH2009PTC195301

Company & Directors' Information:- M M C GLOBAL INDIA PRIVATE LIMITED [Strike Off] CIN = U11200MH2010PTC206910

Company & Directors' Information:- S R GLOBAL PRIVATE LIMITED [Strike Off] CIN = U51109WB1997PTC084553

Company & Directors' Information:- H V GLOBAL PRIVATE LIMITED [Active] CIN = U18101DL2000PTC103960

Company & Directors' Information:- R P GLOBAL PRIVATE LIMITED [Strike Off] CIN = U74990MH2009PTC193409

Company & Directors' Information:- M S GLOBAL PRIVATE LIMITED [Active] CIN = U70100MH2008PTC213273

Company & Directors' Information:- R S V GLOBAL LIMITED [Strike Off] CIN = U51909DL1994PLC059032

Company & Directors' Information:- I S P SOLUTIONS INDIA PRIVATE LIMITED [Active] CIN = U72200TZ2001PTC009755

Company & Directors' Information:- S P E-SOLUTIONS PRIVATE LIMITED [Active] CIN = U72300DL2006PTC155569

Company & Directors' Information:- P N S BUSINESS PRIVATE LIMITED [Active] CIN = U74140WB2005PTC101643

Company & Directors' Information:- M S BUSINESS PRIVATE LIMITED [Active] CIN = U51909MH1997PTC111137

Company & Directors' Information:- J S B BUSINESS PVT LTD [Active] CIN = U27109WB1996PTC078319

Company & Directors' Information:- R S BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140DL2006PTC150819

Company & Directors' Information:- T X G SOLUTIONS PRIVATE LIMITED [Converted to LLP and Dissolved] CIN = U72200DL2006PTC150671

Company & Directors' Information:- H D SOLUTIONS PRIVATE LIMITED [Active] CIN = U72900DL2009PTC194392

Company & Directors' Information:- N B GLOBAL (INDIA) PRIVATE LIMITED [Active] CIN = U15122UP2012PTC051614

Company & Directors' Information:- H & K SOLUTIONS PRIVATE LIMITED [Active] CIN = U63040GJ2009PTC059027

Company & Directors' Information:- A V S BUSINESS PRIVATE LIMITED [Strike Off] CIN = U31908UP2010PTC040437

Company & Directors' Information:- F A S T SOLUTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U22100MH1989PTC052935

Company & Directors' Information:- N AND S SOLUTIONS PRIVATE LIMITED [Active] CIN = U74210KA1999PTC025555

Company & Directors' Information:- U-TO SOLUTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U72100MH2000PTC130052

Company & Directors' Information:- Z D SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72900TN2007PTC062584

Company & Directors' Information:- O AND M SOLUTIONS PRIVATE LIMITED [Active] CIN = U74210OR2005PTC008166

Company & Directors' Information:- A C BUSINESS PRIVATE LIMITED [Strike Off] CIN = U45208MH2009PTC197088

Company & Directors' Information:- R P A S SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200TG2008PTC057538

Company & Directors' Information:- J A J GLOBAL BUSINESS PRIVATE LIMITED [Strike Off] CIN = U24232KA2012PTC065587

Company & Directors' Information:- G L F SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U67190KL2013PTC035455

Company & Directors' Information:- S P SOLUTIONS PRIVATE LIMITED [Amalgamated] CIN = U72200DL2011PTC213318

Company & Directors' Information:- V K BUSINESS PVT LTD [Active] CIN = U21012WB1996PTC079121

Company & Directors' Information:- S. S. G. SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200TG1996PTC023719

Company & Directors' Information:- INDIA CORPORATION PRIVATE LIMITED [Active] CIN = U65990MH1941PTC003461

Company & Directors' Information:- I T SOLUTIONS INDIA PRIVATE LIMITED [Active] CIN = U72200DL1996PTC076426

Company & Directors' Information:- K P BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U67190MH2008PTC180357

Company & Directors' Information:- S P A BUSINESS PVT LTD [Strike Off] CIN = U29296WB1990PTC050043

Company & Directors' Information:- D R V BUSINESS SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200KA2011PTC060623

Company & Directors' Information:- A R G BUSINESS SOLUTIONS PRIVATE LIMITED [Converted to LLP] CIN = U74140DL2008PTC182604

Company & Directors' Information:- S S R BUSINESS SOLUTIONS PVT LTD [Strike Off] CIN = U74140WB2006PTC109483

Company & Directors' Information:- K B SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74140PB2011PTC035055

Company & Directors' Information:- M B BUSINESS SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U51391TN2006PTC058586

Company & Directors' Information:- A D BUSINESS PRIVATE LIMITED [Active] CIN = U74900MH2008PTC178245

Company & Directors' Information:- G AND G BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999TG2011PTC075549

Company & Directors' Information:- A V R BUSINESS PRIVATE LIMITED [Active] CIN = U74992UP2008PTC034629

Company & Directors' Information:- H A SOLUTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U72900DL2000PTC104116

Company & Directors' Information:- B AND E BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140DL2004PTC127141

Company & Directors' Information:- C K BUSINESS PRIVATE LIMITED [Under Process of Striking Off] CIN = U51399DL2003PTC118289

Company & Directors' Information:- C AND D BUSINESS INDIA PRIVATE LIMITED [Strike Off] CIN = U52300KA2010PTC053211

Company & Directors' Information:- V. J. L. SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999UP2018PTC109127

Company & Directors' Information:- 1 TO 5 SOLUTIONS PRIVATE LIMITED [Not available for efiling] CIN = U74999AS2020PTC020427

Company & Directors' Information:- C P H BUSINESS SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200KA1998PTC023742

Company & Directors' Information:- C AND C SOLUTIONS (INDIA) LIMITED [Strike Off] CIN = U93000PY1995PLC001144

Company & Directors' Information:- D E BUSINESS SOLUTIONS LIMITED [Strike Off] CIN = U72900MH1999PLC122852

Company & Directors' Information:- D V M SOLUTIONS LIMITED [Converted to LLP] CIN = U74140DL1999PLC102362

Company & Directors' Information:- T S SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200UP2000PTC025406

Company & Directors' Information:- R R SOLUTIONS PRIVATE LIMITED [Active] CIN = U45309BR2008PTC013387

Company & Directors' Information:- B A SOLUTIONS INDIA PRIVATE LIMITED [Active] CIN = U74999DL2006PTC155492

Company & Directors' Information:- BUSINESS CORPN PRIVATE LIMITED [Strike Off] CIN = U15429UP1945PTC001335

Company & Directors' Information:- C A AND S SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200AP2000PTC034546

Company & Directors' Information:- R A SOLUTIONS PRIVATE LIMITED [Active] CIN = U51101MH2013PTC249132

Company & Directors' Information:- R T W SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200MH2004PTC145773

Company & Directors' Information:- I 2 S BUSINESS SOLUTIONS INDIA PRIVATE LIMITED [Strike Off] CIN = U72200TZ2005PTC011985

Company & Directors' Information:- A E T SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200TG2004PTC036640

Company & Directors' Information:- K N P SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72300TG2011PTC076036

Company & Directors' Information:- I SOLUTIONS(INDIA) PRIVATE LIMITED [Strike Off] CIN = U72900TN2004PTC052692

Company & Directors' Information:- M M BUSINESS PVT LTD [Strike Off] CIN = U51909WB2005PTC106884

Company & Directors' Information:- L K BUSINESS PVT LTD [Active] CIN = U45202WB1985PTC038604

Company & Directors' Information:- T. S. GLOBAL (INDIA) BUSINESS PRIVATE LIMITED [Active] CIN = U74999DL2016PTC303396

Company & Directors' Information:- R V I T SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200DL2005PTC137434

Company & Directors' Information:- R M T SOLUTIONS INDIA PRIVATE LIMITED [Strike Off] CIN = U74210KA2011PTC056861

Company & Directors' Information:- E M C SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200KA1996PTC020112

Company & Directors' Information:- R I SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U52392WB1999PTC088640

Company & Directors' Information:- T R BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999TN2012PTC088097

Company & Directors' Information:- L S SOLUTIONS PRIVATE LIMITED [Active] CIN = U67190DL2020PTC371664

Company & Directors' Information:- 9 I SOLUTIONS PVT LTD [Strike Off] CIN = U72200TG2005PTC048565

Company & Directors' Information:- S G SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999BR2008PTC013392

Company & Directors' Information:- K P N SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74900KA2011PTC057705

Company & Directors' Information:- BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74910WB1999PTC090820

Company & Directors' Information:- V N SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74900DL2009PTC195421

Company & Directors' Information:- C L BUSINESS PRIVATE LIMITED [Active] CIN = U93000WB2014PTC202032

Company & Directors' Information:- R. K. SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140DL2007PTC161367

Company & Directors' Information:- J K B SOLUTIONS INDIA PRIVATE LIMITED [Strike Off] CIN = U74900DL2015PTC284162

Company & Directors' Information:- S R SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200HR2000PTC055629

Company & Directors' Information:- B E SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200KA2005PTC037127

Company & Directors' Information:- G R K SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72900TG2002PTC039029

Company & Directors' Information:- A. P. V. BUSINESS PRIVATE LIMITED [Strike Off] CIN = U14299RJ2017PTC058759

Company & Directors' Information:- G N SOLUTIONS PRIVATE LIMITED [Active] CIN = U65993PN2008PTC132031

Company & Directors' Information:- J .S .SOLUTIONS PRIVATE LIMITED [Active] CIN = U72900PB2007PTC030855

Company & Directors' Information:- R Z BUSINESS AND SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72300MH2013PTC248460

Company & Directors' Information:- TAX-O-TAX SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74120PN2004PTC020069

Company & Directors' Information:- SOLUTIONS @ PANORAMA TRAVEL PRIVATE LIMITED [Strike Off] CIN = U63040MH2010PTC199347

Company & Directors' Information:- A & J BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74900PN2015PTC155484

Company & Directors' Information:- A.N.D SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999MH2013PTC244625

Company & Directors' Information:- A M GLOBAL PRIVATE LIMITED [Active] CIN = U74999MH2015PTC261061

Company & Directors' Information:- J V B BUSINESS PRIVATE LIMITED [Active] CIN = U74999MH2016PTC282145

Company & Directors' Information:- V & M SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999PN2014PTC150848

Company & Directors' Information:- G K SOLUTIONS PRIVATE LIMITED [Active] CIN = U72900MH2004PTC149891

Company & Directors' Information:- G K A SOLUTIONS PRIVATE LIMITED [Active] CIN = U72900MH2004PTC150210

Company & Directors' Information:- K & S BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74120MH2013PTC246122

Company & Directors' Information:- H. R. SOLUTIONS INDIA PRIVATE LIMITED [Strike Off] CIN = U74120TG2012PTC081581

Company & Directors' Information:- U & C BUSINESS CORPORATION PRIVATE LIMITED [Strike Off] CIN = U51909TG2014PTC095129

Company & Directors' Information:- K R K BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U72300TG2012PTC085156

Company & Directors' Information:- A R M G BUSINESS PRIVATE LIMITED [Strike Off] CIN = U51909UP2013PTC055405

Company & Directors' Information:- A & J GLOBAL SOLUTIONS PRIVATE LIMITED [Active] CIN = U74900TG2014PTC096042

Company & Directors' Information:- L S A GLOBAL INDIA PRIVATE LIMITED [Under Process of Striking Off] CIN = U74900TG2015PTC098308

Company & Directors' Information:- E-TAX SOLUTIONS PRIVATE LIMITED [Active] CIN = U74900TG2015PTC099401

Company & Directors' Information:- U K BUSINESS PRIVATE LIMITED [Active] CIN = U74999UP2016PTC086597

Company & Directors' Information:- S A E-SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200WB2012PTC181964

Company & Directors' Information:- K. S. E-SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74999WB2012PTC185025

Company & Directors' Information:- O S SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U93000JK2012PTC003733

Company & Directors' Information:- R L GLOBAL INDIA PRIVATE LIMITED [Strike Off] CIN = U52300HP2014PTC000764

Company & Directors' Information:- B AND P SOLUTIONS PRIVATE LIMITED [Active] CIN = U24100CH2015PTC035482

Company & Directors' Information:- A T SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72900CH2009PTC031621

Company & Directors' Information:- R AND D SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U52392CH2010PTC032232

Company & Directors' Information:- G S L SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72300DL2007PTC164747

Company & Directors' Information:- F K SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72900DL2008PTC186101

Company & Directors' Information:- B. R. SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140DL2002PTC116699

Company & Directors' Information:- G. M. S E-SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74140DL2012PTC235662

Company & Directors' Information:- A N S SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74140DL2012PTC245060

Company & Directors' Information:- S & T SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74140DL2013PTC247089

Company & Directors' Information:- A & A BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140DL2013PTC262803

Company & Directors' Information:- M A SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140DL2014PTC265618

Company & Directors' Information:- S A N SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999DL2002PTC117534

Company & Directors' Information:- F T R BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999DL2013PTC254967

Company & Directors' Information:- L M BUSINESS SOLUTIONS PRIVATE LIMITED [Under Process of Striking Off] CIN = U74999DL2015PTC278623

Company & Directors' Information:- I G SOLUTIONS PRIVATE LIMITED [Active] CIN = U70109DL2012PTC244223

Company & Directors' Information:- S N R SOLUTIONS PRIVATE LIMITED [Active] CIN = U72100DL2011PTC216142

Company & Directors' Information:- P G I T SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200DL2005PTC139469

Company & Directors' Information:- H R SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74899DL1995PTC073143

Company & Directors' Information:- A 2 Z SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74899DL2001PTC109658

Company & Directors' Information:- A P D SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74900DL2013PTC249969

Company & Directors' Information:- R N BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74900DL2013PTC254975

Company & Directors' Information:- A N TAX SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74900DL2013PTC256159

Company & Directors' Information:- GLOBAL TAX SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74900DL2013PTC257765

Company & Directors' Information:- V R A A P SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74950DL2014PTC271337

Company & Directors' Information:- D N GLOBAL SOLUTIONS PRIVATE LIMITED [Active] CIN = U63000DL2012PTC238872

Company & Directors' Information:- 7 O 3 BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140HR2012PTC046085

Company & Directors' Information:- R - N - A E - SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74900KA2008PTC045680

Company & Directors' Information:- V SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200KA2010PTC052832

Company & Directors' Information:- G R GLOBAL PRIVATE LIMITED [Active] CIN = U70102KA2013PTC069586

Company & Directors' Information:- N R L SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72900KA2013PTC069148

Company & Directors' Information:- S V SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74140GJ2007PTC051390

Company & Directors' Information:- H. E. GLOBAL PRIVATE LIMITED [Active] CIN = U72901GJ2016PTC092866

Company & Directors' Information:- N. D. GLOBAL SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999GA2019PTC013951

Company & Directors' Information:- A & A SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200PN2008PTC131887

Company & Directors' Information:- T N B SOLUTIONS PRIVATE LIMITED [Active] CIN = U72900MH2007GAT171606

Company & Directors' Information:- H F SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72300DL2007PTC168577

Company & Directors' Information:- K V M SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72900DL2008PTC180136

Company & Directors' Information:- A R C O N SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200KL2007PTC020421

Company & Directors' Information:- T & T SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72900GJ2007PTC051103

    Income Tax Appeal No. 616 of 2016

    Decided On, 16 July 2018

    At, High Court of Karnataka

    By, THE HONOURABLE MR. JUSTICE VINEET KOTHARI & THE HONOURABLE MRS. JUSTICE S. SUJATHA

    For the Appearing Parties: Nageswar Rao, K. Mallaha Rao, Sandeep S Karhail, Advocates.



Judgment Text

Vineet Kothari, J.

1.The Assessee M/s Swiss Re Global Business Solutions India Private Limited has filed this appeal u/s 260A of the Income Tax Act, 1961 ('Act' for short) raising the following purported substantial questions of law from the Order of the Income Tax Appellate Tribunal, 'A' Bench, Bangalore, in IT [TP] A No.380/Bang/2016 dated 08.07.2016 relating to the Assessment Year 2011-12.

2. The substantial questions of law suggested by the Assessee in the Memorandum of Appeal are as under:

"a) Whether in the facts and circumstances of present case, Tribunal's decision to uphold inclusion of M/s ICRA Online Limited in set of comparable companies to the Appellant-Assessee is perverse and contrary to law and facts?

b) Whether remand to Assessing Officer/TPO to verify comparability of M/s Jeevan Scientific Technologies Ltd., is totally justified and whether Appellant is entitled to final and conclusive determination on the issue by Tribunal?"

3. Though prima facie the question about the selection of comparables are finding of facts, which are binding on this court and unless an ex-facie perversity is in the Order of the learned Tribunal is established, in our considered view, no substantial question of law arises on such issues and we have recently rendered a Judgment in I.T.A. Nos.536/2015 c/w 537/2015 dated 25.06.2018 (Prl. Commissioner of Income Tax & Anr. v- M/s Softbrands India Pvt. Ltd.,) expressing the aforesaid opinion in a more detailed manner. Our conclusions in the Judgment are quoted below for ready reference:

"Conclusion:

55. A substantial quantum of international trade and transactions depends upon the fair and quick judicial dispensation in such cases. Had it been a case of substantial question of interpretation of provisions of Double Taxation Avoidance Treaties (DTAA), interpretation of provisions of the Income Tax Act or Overriding Effect of the Treaties over the Domestic Legislations or the questions like Treaty Shopping, Base Erosion and Profit Shifting (BEPS), Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals of the present tenor as to whether the comparables have been rightly picked up or not, Filters for arriving at the correct list of comparables have been rightly applied or not, do not in our considered opinion, give rise to any substantial question of law.

56. We are therefore of the considered opinion that the present appeals filed by the Revenue do not give rise to any substantial question of law and the suggested substantial questions of law do not meet the requirements of Section 260-A of the Act and thus the appeals filed by the Revenue are found to be devoid of merit and the same are liable to be dismissed.

57. We make it clear that the same yardsticks and parameters will have to be applied, even if such appeals are filed by the Assessees, because, there may be cases where the Tribunal giving its own reasons and findings has found certain comparables to be good comparables to arrive at an 'Arm's Length Price' in the case of the assessees with which the assessees may not be satisfied and have filed such appeals before this Court. Therefore we clarify that mere dissatisfaction with the findings of facts arrived at by the learned Tribunal is not at all a sufficient reason to invoke Section 260-A of the Act before this Court.

58. The appeals filed by the Revenue are therefore dismissed with no order as to costs."

4. However, learned counsel for the Assessee Mr.Nageshwar Rao specifically drew our attention to the finding of the learned Tribunal with respect to two comparables viz., M/s ICRA Online Limited and M/s Jeeven Scientific Technologies Ltd, (seg), in paragraphs 28 to 31 of the Order of the learned Tribunal, which we quote below for ready reference:

"28. Type of work being done by the assessee captured by us at para three above would show that assessing was also doing analysis of results, testing and calibration etc., I had to use market intelligence, maintain e-tools and provide reporting analytics. In our opinion the level of expertise being used by the assessee in its technology enabled services and that being used by ICRA Online Ltd, were comparable, though they were in different streams of operation. Hence we are one with the argument of Ld. DR that exact fitting in the mould of comparables is not necessary in a TNMM study. However, once the level of knowledge that is being used for the outsourcing is on a reasonably comparable pedestal, the type of service industry to which the concerns cater may not matter much. In the case of Ramgreen Solutions P. Ltd, , their Lordship had observed that there could be different level of skill sets used within the very same ITES services and a comparison can be attempted only after making a proper analysis of the skill sets that were being employed. In our opinion considering the observation of their Lordship in Rampgreen Solutions P. Ltd, , ICRA Online Ltd, was correctly considered by the lower authorities as a proper comparable. We do not find any reason to interfere with the orders of authorities below in this regard.

29. Seeking exclusion of Jeevan Scientific Technologies Ltd, (seg), Ld. AR submitted that the turnover of the said company was less than Rs. 1 crore. As per the Ld. AR, TPO himself had excluded companies having turnover below Rs. 1 crore. Relying on paper book, page 719, which is a part of the annual report report Jeevan Scientific Technologies Ltd. (seg), Ld. AR submitted that the revenue from BPO operations of the said company came to only Rs. 79.21 lakhs. As per the Ld. AR, the total operating revenue of the said company for the relevant previous year was only Rs. 2.49 crores of which substantial part was from other streams of operation.

30. Per contra, Ld.DR submitted that the segment considered by the TPO had a turnover of Rs. 246,75,00,000/-. Thus according to him Jeevan Scientific Technologies Ltd, (seg), was a good comparable.

31. We have heard the rival contentions. Audited balance sheet and financial statement of Jeevan Scientific Technologies Ltd, (seg), taken from capitaline data base has been filed before us by the assessee at paper book page.677 to 740. Net revenue of the said company for the relevant previous year from its operation was Rs. 2,45,39,231/-, as per its income statement at paper book page 725. TPO had considered the revenue as Rs. 2,46,75,000/-. However segmental revenue of the said company, as it appear at paper book page 719 show its earning from BPO operations is Rs. 71.219 lakhs. Thus TPO had considered the total revenue instead of the segmental revenue. The turnover of the segment which was being compared was less than Rs. 1 crore and by the yardstick applied by the TPO himself, the company ought have been excluded from the list of comparables. Whether the segmental information of the said company given by the assessee at paper book page 719, nevertheless requires a verification. We therefore set aside the comparability of Jeevan Scientific Technologies Ltd, (seg), back to the file of the AO/TPO for consideration afresh. In case the earning of the said company from its BPO operation is less than Rs. 1 crore it has to be excluded from the list of comparables."

5. As far as the second comparable M/s Jeevan Scientific Technologies Ltd (seg) is concerned, the learned Tribunal has only remanded the case back to the file of AO/TPO for fresh consideration and therefore, we are of the opinion that selection of that comparable has not yet become final at the hands of AO/TPO. AO/TPO have to look into the facts and figures with regard to the said comparable once again. Though the learned counsel for the appellant-Assessee apprised this court that in pursuance of the learned Tribunal's order, the learned TPO has reiterated its previous order and even Misc. Application filed before the learned Tribunal came to be rejected by the learned Tribunal on 22.2.2017. We are not presently seized of any appeal arising from such later order, nor these later orders are part of the record of this appeal. As far as the present order of the learned Tribunal is concerned, we do not find any substantial question of law to be arising with regard to the said company-M/s Jeevan Scientific Technologies Ltd (seg).

6. As far as the other comparable- M/s ICRA Online Ltd., is concerned, learned counsel for Assessee emphasized that the said comparable M/s ICRA Online Ltd. was a Knowledge Processing Outsourcing (KPO) company, whereas the Assessee company was providing low end Business Processes Outsourcing (BPO) services. Learned counsel drew our attention to the Judgment of the Division Bench of Delhi High Court in the case of Rampgreen Solutions Pvt. Ltd. v- Commissioner of Income Tax, (2015) 377 ITR 533 decided on 10.08.2015 in ITA No.102/2015, in which the Division Bench of Delhi High Court has quoted Rule 10TA(g) of the Income-Tax Rules, 1962 which defines KPO service as under:

"(g) "knowledge process outsourcing services" means the following business process outsourcing services provided mainly with the assistance or use of information technology requiring application of knowledge and advanced analytical and technical skills, namely:-

(i) geographic information system;

(ii) human resources services;

(iii) engineering and design services;

(iv) animation or content development and management;

(v) business analytics;

(vi) financial analytics; or

(vii) market research,

but does not include any research and development services whether or not in the nature of contract research and development services;"

7. Learned counsel submitted that KPO services are high end Information Technology Enabled Services (ITES), whereas the Assessee-Company in the present case was providing Voice Call Services, which is a low end type of service of ITES and therefore, the said comparable has been wrongly selected by the TPO and the learned Tribunal has fallen in error in upholding the said comparable with the case of the Assessee.

8. We find ourselves unable to agree with the said submission of the learned counsel for the appellant Assessee. From the aforesaid quoted definition of KPO, it appears to be a specie of genus BPO and both being ITES services provided by the Software industry to their clients, the area of KPO may fall in the indicated areas of operation and the exclusion as specified in Rule 10TA(g) is only for Research and Development Services whether or not in the nature of contract Research and development services, but we do not find any water tight compartment or any specified classification of KPO and other types of BPOs in Rule 10TA. If the concerned KPO which falls within the definition of genus category of BPO as per the segmental information available in public domain, the Assessee could very well persuade the Authorities below to compare only segmental information so available in public domain, but we cannot accept the broad submission made at the Bar by the learned counsel for the appellant-Assessee that since the declared comparable- M/s ICRA Online Ltd., was a KPO, therefore, the same should not be compared with the case of the Assessee, because as per its own TPO analysis, it was engaged only in low end BPO services viz., Voice Call Centre etc., and on the said basis, we do not find that the reasons assigned by the learned Tribunal in paragraph 28 of its order, quoted above, are perverse or lack any foundation in that regard.

9. The learned Tribunal has clearl

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y noted that though the comparable ICRA Online Ltd., and the Assessee were in different stream of operations, but the comparables need not exactly fit in the mould of comparables while adopting the TNMM study for arriving at the Arm's Length Price for the purpose of Chapter-X of the Act. 10. The learned Tribunal, in our opinion, has rightly observed in paragraph 28 that once the level of knowledge that is being used for Outsourcing is at a reasonably comparable pedestal, the type of service industry to which the comparable company and the Assessee-Company cater may not matter much. 11. In our afore cited Judgment in the case of Soft Brands we have already observed that the Court u/s 260A of the Act cannot itself engage in undertaking the study of the comparables itself nor it has any wherewithal, the necessary facts and figures and expertise to undertake such a hairsplitting exercise at its own end and the perversity in the findings of the learned Tribunal to invoke the jurisdiction of this court u/S 260-A of the Act has to be palpable, explicit and established on the face of it. No such infirmities are found in the present order of the learned Tribunal before us. Therefore, no substantial question of law arises for our consideration. The appeal of Assessee thus stands dismissed. No costs.
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