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2017 (9) TMI 2013 - HC - Income TaxTP Adjustment - comparable selection - omission by the ITAT of Celestial Labs Ltd. from the list of comparables - HELD THAT:- This Court finds that the ITAT has itself undertaken a detailed analysis of the functional profile of the tested company vis-a-vis that of the comparable and has given cogent reasons for excluding the said comparable. The Court is not persuaded to hold that this factual finding is perverse. It accordingly declines to frame a question on this issue. Nature of expenses - Expenditure incurred on software licenses - capital or revenue expenditure - HELD THATR:- The decision of this Court in CIT v. Asahi India Safety Glass Ltd [2011 (11) TMI 2 - DELHI HIGH COURT] answers this very issue against the Revenue. The Supreme Court dismissed the Special Leave Petition filed by the Revenue against the said decision. [2012 (7) TMI 1075 - SC ORDER] In view of that matter, the Court declines to frame a question on this issue as well.
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