Section 92C of the Income Tax Act, 1961 — Transfer Pricing — Computation of arms length price- Assessee is carrying on business through its own employee and has incurred almost 59% of its total cost on employees cannot be compared with a company which is getting its work done through outside vendor and not by employing its own human resources. Assessee being an information technology enabled services provider engaged in back office operations, revenue accounting and Call Centre services cannot be compared with a company which is rendering structural engineering KPO services — American Express India P. Ltd. vs. Deputy Commissioner of Income tax [2018 ]196 TTJ (Delhi) 283