Maersk Global Centres (India) Pvt. Ltd vs. ACIT (ITAT Mumbai Special Bench) Transfer Pricing: Companies in ITES cannot be classified into low-end BPO services and high-end KPO services for comparability analysis but have to be classified based on the functions performed. Comparables with abnormal profit margins cannot be discarded per se but must be examined to determine whether the high margins are due to normal business conditions or notÂ