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2019 (7) TMI 1963 - HC - Income TaxTP Adjustment - International transactions/activities in respect of one of the services rendered to its associated enterprises i.e. (AE) - Assessee was engaged in knowledge management systems - Whether ITAT erred in concluding that for the AYs in question, the Assessee had rendered Knowledge Process Outsourcing (KPO) services to its Associated Enterprises which according to the Assessee was contrary to the documents on record? - Revenue on the other hand points out that for these very AYs, on the question of exclusion of comparables, the Revenue's appeals against the impugned order of the ITAT have been dismissed by this Court - HELD THAT:- In view of the above submission, it is considered appropriate to direct that the impugned order of the ITAT returning the above finding qua the activity of the Assessee for the AYs in question will not constitute a precedent if such issue were to arise in future in the Assessee's cases. In other words, the question framed by the Court for consideration in these appeals is left open for decision in an appropriate case.
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