Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2020 (11) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2020 (11) TMI 1089 - ITAT DELHITP Adjustment - Comparable selection - exclusion of three companies, namely M/s. Accentia Technologies Ltd., M/s. Eclerx Services Ltd. and M/s. Acropetal Technologies Ltd. from the list of comparable companies - HELD THAT:- As far as the exclusion of Accentia Technologies Ltd. is concerned, we find that CIT(A) after considering the submission of the assessee has given a finding that it is engaged in rendering high end services and the nature of its activities are more in the nature of KPO services whereas the services rendered by the Assessee are of ITeS Services. He has therefore held Accentia Technologies Ltd. to be not a comparable to that of assessee. With respect to Acropetal Technologies Ltd. and Eclerx Services Ltd., we find that CIT(A) has noted that in assessee’s own case for A.Y. 2008-09, CIT(A) had held these two companies to be functional dissimilar to that of assessee. He has further noted that there are no changes in the facts and circumstances in the year under consideration and that of A.Y. 2008-09. Before us, no fallacy in the findings of CIT(A) has pointed out by the Revenue. In such a situation, we find no reason to interfere in the order of CIT(A) and thus the ground of Revenue is dismissed.
|