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M/s. Equant Solutions India Pvt. Ltd Versus ACIT, Circle-1, Gurgaon.

2016 (1) TMI 115 - ITAT DELHI

Transfer pricing adjustment - selection of comparable - Held that:- From a perusal of the order of the DRP, it is clear that the assessee’s objections / contentions against the inclusion/exclusion of the comparables has not been dealt by the DRP while exercising the appellate jurisdiction against a quasi-judicial order of the TPO, which exercise is sine qua non for deciding the issue as to whether a comparable is comparable to the FAR of the tested party i.e. assessee. Simply by observing that t .....

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. Ex consequenti, the DRP order is set aside and the matter remanded back to the file of the DRP for passing a speaking order in respect of all the grounds raised before it and has to deal with each of the comparables contested above by the assessee. Needless to say that when considering the arguments in respect to selection of the comparables, the DRP must keep in mind the following aspects:-

(a) Companies with extra ordinary circumstances, like those which suffered events like merge .....

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dressing the objections in respect to inclusion / exclusion of comparables and pass a speaking order after giving adequate opportunity to the assessee. - Decided in favour of assessee for statistical purposes - ITA No.5520/Del./2011 - Dated:- 18-9-2015 - SHRI J.S. REDDY, ACCOUNTANT MEMBER AND SHRI A.T. VARKEY, JUDICIAL MEMBER For The Assessee : Shri Kanchan Kaushal, FCA and Shri Ravi Sharma Advocate For The Revenue : Shri Bhaskar Goswami, Senior DR ORDER PER A.T. VARKEY, JUDICIAL MEMBER : This a .....

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two segments :- (i) Information Technology enabled Services (hereinafter referred to as 'ITES') - Information technology enabled network management / technical support and other back-office support services in the nature of remote monitoring and maintenance of the Equant's global network platforms and services, coordination and remote configuration and implementation of quality customer networking solutions to its Group Company in Ireland, Equant Network Services International Ltd. .....

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ons with its AEs which were duly reported in the Accountant's Report (Form No 3CEB) filed along with the return:- Particulars (International Transactions) Adjustment Outcome of TP Order after DRP Directions Provision of ITES and CSD services 97,11,94,161 Adjustment of Rs. 13.044,743 on CSD services and Rs. 75,513,180 on ITES services Purchase of fixed assets 3,42,43,723 Accepted Interest on loan (paid) 1,60,71,371 Accepted Reimbursement of expenses paid 4,73,41,015 Accepted 4. During the cou .....

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% 3.52% Assessee s OP/TC 15% 5. The TPO proposed an adjustment of Rs.l,30,44,743 to the income from the CSD segment and an adjustment of ₹ 7,55,13,180 to the income from the ITES segment. The above adjustment made by the TPO to the income of the assessee was upheld by the Assessing Officer (hereinafter referred to as 'AO') in his draft assessment order. The assessee filed detailed objections before the Dispute Resolution Panel (hereinafter referred to as 'DRP') against the .....

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ost-DRP direction : S.No. Name of the company 1. Accel Transmatic Ltd (Seg.) 20.91% 19.5% 2. Avani Cimcon Technologies Ltd. 50.28% 47.81% 3. Celestial Labs Ltd. 58.35% 53.14% 4. Datamatics Ltd 1.38% - 1.31% 5. E-Zest Solutions Ltd. 35.63% 34.58% 6. Flextronics Software Systems Ltd. (Seg.) 25.31% 24.15% 7. Geometric Ltd. (Seg.) 10.71% 8.84% 8. Helios & Matheson Information Technology Ltd. 36.63% 33.46% 9. IGate Global Solutions Ltd. 7.49% 4.87% 10. Infosys Technologies Ltd 40.30% 37.96% 11. I .....

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cation Technologies Ltd. 22.17% 20.21% 23. SIP Technologies & Exports 13.90% 9.91% 24. Tata Elxsi Ltd. (Seg.) 26.51% 25.26% 25. Thirware Solutions Ltd. (Seg.) 25.12% 20.65% 26. Wipro Ltd. (Seg.) 33.43% 33.27% Mean OP / TC 25% 22.13% ITES - TP ORDER COMPARABLES S.No. Name of the company 1. Accentia Technologies Ltd 30.61% 25.52% 2. Aditya Birla Minacs Worldwide Ltd. 11.98% 10.52% 3. Allsec Technologies Ltd. 27.31% 25.08% 4. Apex Knowledge Solutions Pvt. Ltd 12.83% 12.51% 5. Apollo Healthstree .....

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chno Analytics Ltd. (Seg.) 12.24% 10.92% 16. Informed Technologies India Ltd. 35.56% 34.12% 17. Infosys B P O Ltd 28.78% 27.97% 18. IServices India Pvt Ltd 49.47% 47.79% 19. Maple Esolultions Ltd. 34.05% 29.54% 20. Mold- Tek Technologies Ltd 113.49% 113.97% 21. R Systems International Ltd. (Seg.) 20.18% 17.74% 22. Spanco Ltd. (Seg.) 25.81% 19.05% 23. Triton Corp Ltd. 34.93% 27.01% 24. Vishal Information Technologies Ltd. (Coral Hub Limited) 51.19% 41.58% 25. Wipro Ltd. (Seg.) 29.70% 29.40% 26. N .....

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mpany's website, it is involved in provision of IT and related services and owns software products, like, DXchange, Travel Solutions, Insurance Solution, Customer Appreciation and Relationship Management Application (CARMA), Content Management Systems etc. its website, Avani has provided year wise milestones achieved wherein it is stated that product DXchange was introduced in 2006 and the improved version in the year 2007. 8.2 The following case laws have been relied upon by the ld. AR :- & .....

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Intoto Software India Put. Ltd. (ITA.No.1196/Hyd/2010)(AY 2005-06), • ITA No.1197/Hyd/2010 (AY 2005-06), • ITA.No.2102/Hyd/2011 (AY 2007-08) (ii) Celestial Labs Limited ('Celestial') 8.4 Ld. AR contended that this comparable owns products and took our attention to Exhibit 2. According ot ld. AR, the Celestial company is primarily into development of software tools as products for application in the field of bio technology, pharmaceutical and health care industry. Eg: Celsuite t .....

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• Tata McGraw Hill Education Pvt. Ltd (ITA No.5857/Del/2011) (AY 2007-08), • LGS Global Ltd (formerly known as Lanco Global Systems Ltd (ITA No. 1885,/Hyd/2011) CAY 2007-08). (iii) Felxtronics Software Systems Limited ('Flextronic') (Segmental) 8.6 Ld. AR submitted that details show that this comparable company owns products and took our attention to Exhibit 3. According to ld. AR, Flextronics has launched a new product in FY 2006-07 named CAS (Converged Active Solution), and a .....

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re, no bifurcation is available between the two activities of the Company. 8.8 Ld. AR relied upon the following case laws :- • Toluna India (ITA No.5645/Del/2011) (AY 2007-08) • DE Shaw India Software Pvt. Ltd (ITA No. 2071/Hyd/2011) (2007-08). (iv) Thirdware Solutions Limited ('Thirdware') (Segmental) 8.9 Ld. AR contended that this comparable is enaged in sale of software products and took our attention to Exhibit 4. According to ld. AR, as per the Annual Report of FY 2006-07, .....

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2007-08). • 3DPLM Software Solutions Ltd. (Successor to Delmia Solutions Pvt Ltd) (IT(TP) A.NO.1303/Bang/2012 (AY 2008-09) (v) E-Zest Solutions Limited ('E-Zest') - 8.12 According to ld. AR, this company has diversified business and took our attention to Exhibit 5. According to ld. AR, based on the company website, it undertakes diversified activities. It provides services such as custom software development, CRM ERP, Open Source ERP, Knowledge management consulting, health care man .....

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nology Limited ('Helios') 8.14 Ld. AR contended that this comparable fails employee cost filter and took our attention to Exhibit 6. He pointed out that company fails employee cost filter applied by the TPO which are as below :- Particulars Amount Income from software sales and services (A) 1,786,380,304 Staff Welfare (B) 186,43,728 Employee cost / sales (B/A) 1.04% Also, the ld. AR submitted that the company provides various diversified services, like, application management services, I .....

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culars Amount Sales (A) 74,209,887 Salary and staff welfare (B) 2,935,065 Director s remuneration (C) 1,00,000 Total Employee cost (D=B+C) 3,935,065 Employee cost / sales (D/A) 5.30% 8.17 Ld. AR relied on the following case laws :- • DE Shaw India Software Pvt Ltd (ITA No. 2071/Hyd/2011)(AY 2007-08) • Virtusa (India) Pvt Ltd (ITA No.1962/Hyd/2011)(AY 2007-08) • Motorola Solutions India Pvt Ltd (ITA No.5637/Del/2011)(AY 2007-08) • Invensys Development Centre India Pvt Ltd (ITA .....

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S has revenue of 23% from trading in software and revenue earned from training is 4%, which are as under :- Total Sales (A) 20,905,322 Income from software development- Export Sale (B) 20,009,937 Revenue- Training (C) 862,400 Change in inventory during the year (1,36,08,315-1,01,22,401) (D) 3,485,914 Mark-up earned on cost (E) 30.55% Sales value- Inventory (F= D+ D*E) 4,550,861 Percentage revenue from trading (F/B) 23% Percentage revenue from training (C/A) 4% 8.19 Ld. AR relied upon the followi .....

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Propertu Services P.Ltd (ITA NO.1124/Bang/2011) • Pyramid IT consulting Pvt. Ltd (ITA No. 5401/DEL2012)(AY 2008-09) (ix) Megasoft Limited ('Megasoft') 8.20 Ld. AR submitted that amalgamation took place in this year and took our attention to Exhibit 9. He submitted that the company has undergone business restructuring activities during the year where in the business performance of Visual Soft Technologies Limited, w.e.f. October 1, 2006 has been amalgamated with the financial perfor .....

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(AY 2007-08). 8.23 Ld. AR submitted that the company derives its income from the sale of software services as well as products. Since the annual report does not provide any further break-up of income into products and services, the Company cannot be treated as functionally comparable to the assessee. He submitted that the segmental information is also available. 8.24 He relied on the following case laws :- • Intoto Software India Put. Ltd. [ITA.No.1196/Hyd/201)(AY 2005- 06) • ITA No.11 .....

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s :- • Tata McGraw Hill Education Pvt Ltd (ITA No. 5857/Del2011)(AY 2007-08). • Toluna India (ITA No.5645/Del/2011) (AY 2007-08) • Motorola Solutions India Pvt Ltd (ITA No. 5637/Del/2011)(AY 2007-08) 8.27 Ld. AR submitted that also, as per the annual report of the company for FY 2006-07, the Company owns significant amount of intangibles amounting to ₹ 95.34 crores. 8.28 He relied on the decision in the case of Motorola Solutions India Pvt Ltd (ITA No. 5637/Del/2011) (AY 200 .....

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x 700 times the turnover of assessee of ₹ 17 crores from the CSD services), therefore, should be rejected based on established judicial precedents by the Hon'ble Delhi High Court in the case of Agnity India Technologies Ltd. (ITA 1204/2011) which rejected Infosys on various factors, which includes factors such as turnover, capital, advertising, sales promotion and brand building expenses, and expenditure on R&D. 8.31 Ld. AR further submitted that Infosys has substantial intangible .....

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n as Lanco Global Systems Ltd (ITA No. 1885/Hyd/2011)(AY 2007-08) • Toluna India (ITA No.5645/Del/2011)(AY 2007-08) 8.33 Ld. AR submitted that also, Infosys owns products/ IPR and leverages on its premium banking solution Finacle R as evidenced by its annual report for IT 2006-07 and the company also undertakes significant expenditure on R&D as is evident from its annual report. He submitted that standalone segmental information for software development services is not available. 8.34 L .....

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and took our attention to Exhibit 13. He submitted that the sales/ turnover of Wipro for FY 2006-07 is INR 9,669 crores (considering only the IT services segment) as against the assessee's total sales/ turnover of merely INR 17 crores pertaining to the provisio of IT services. He submitted that it would be absurd to compare the assessee with companies having turnover is more than 500 times the size of the assessee. 8.36 Ld. AR relied on the following case laws :- • Toluna India (ITA No .....

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C/2011) 8.37 Ld. AR further submitted that the Standalone financial data of Wipro for FY 2006-07 is not available in the public domain. He submitted that the annual report of the company for FY 2006-07 provides the abridged financial data which would not provide the detailed financial information that would be required to determine the comparability of the company. 8.38 Ld. AR relied on the following case laws :- • Tata McGraw (ITA No.857/Del/2011) • Witness Systems Software India Pvt .....

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n this year and took our attention to Exhibit 14. Ld. AR submitted that during FY 2006-07, an amalgamation occurred wherein Accentia took over Iridium Technologies and Geosoft technologies. 9.2 Ld. AR relied on the following case laws:- • Capital 10 Information Systems (India) Pvt. Ltd (ITA No.1961/Hyd/2011)(AY 2007-08) • Zavata India Private Limited (ITA No.1781/Hyd/2011)(AY 2007- 08) • Avineon India Pvt Ltd (ITA No.1989/Hyd/2011)(AY 2007-08) • Stream International Services .....

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cost to total cost filter of 25% as applied by the TPO. Ld. AR further submitted that the company has an employee cost to sales ratio of 24.79% as under :- Sales (Operating) 63,415 Employee Cost 15,720 Employee cost/ Sales 24.79% 9.5 He relied on the decision in the case of Zavata India Private Limited (ITA No.1781/Hyd/2011) (AY 2007-08). 9.6 Ld. AR submitted that the company is engaged in the provision of high-end services in the nature of GIS services and mobile assets tracking. Further, the .....

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30, 2007. (xvii) Informed Technologies India Limited ('Informed') 9.9 Ld. AR submitted that this company fails the employee cost filter and took our attention to Exhibit 17. He submitted that the company fails the employee cost to total cost filter of 25% as applied by the Ld. TPO. The company has an employee cost to sales ratio of 21. 77% during FY 2006-07 as under :- Sales and services 40,776,342 Employee cost (B) 8,876,921 Employee cost/ Revenue (B/A) 21.77% 9.10 Further, ld. AR subm .....

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nally different :- (xviii) Bodhtree Consulting Limited (Segmental) ('Bodhtree') 9.13 Ld. AR submitted that this comparable company is engaged in the business of software development and took our attention to Exhibit 18. He submitted that Bodhtree is a software development and product company which cannot be considered similar to ITES services provided by the assessee. Further, he submitted that the TPO himself has considered Bodhtree as a comparable to the assessee's CSD segment in A .....

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e data analytics services performed by Eclerx is functionally different and are more value adding and high end in nature compared to the routine outsourced service functions performed by the assessee under ITES segment. He submitted that the segmental data not available and company also states it is not comparable to BPO and also owns significant JP. 9.16 Ld. AR relied on the following case laws:- • Zavata India Private Limited [TS-156-ITAT-2013-HYD)-TP] (AY 2007-08 • Stream Internatio .....

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(xx) Genesys International Corporation Limited ('Genesys') 9.17 Ld. AR submitted that this comparable company is engaged in the business of High End KPO Services and took our attention to Exhibit 19. He submitted that Genesys is mainly engaged in the area of Geographical Information System Services and the GIS services performed by Genesys are functionally different from the functions performed by the assessee under its IT enabled services segment which are primarily in the nature of bac .....

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ged in the business of High End KPO Services and took our attention to Exhibit 20. He submitted that Mold -Tek is engaged in the business of rendering engineering services in the nature of GIS services which are higher-up on the value chain which cannot be compared with back office support services such as network, data and helpdesk services provided by the assessee. 9.19 Ld. AR relied on the following case laws :- • Stream International Services Pvt Ltd [TS-312-ITAT-2014(Mum -TP] AY (2007- .....

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Ltd (ITA NO.140…./Hyd/2013) • Capital IQ Information Systems (India) Pvt. Ltd. (ITA No.1961/Hyd/2011)(AY 2007-08). 9.21 Ld. AR submitted that the company has a relatively low employee cost/ sales ratio (approx 8%) as against the employee cost/ sales ratio for the assessee as under :- Particulars Amount (in INR) Income from operations (A) 881,188 Employees Remuneration & Benefits (B) 66,881 Employee cost / sales (B) / (A) 7.59% 9.22 Ld. AR relied on the decision of Avineon India P .....

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laws :- • Zavata India Private Limited (ITA No.1781/Hyd/2011)(AY 2007- 08) • Avineon India Pvt Ltd (ITA No.1989/Hyd/2011)(AY 2007-08) • Capital IQ Information Systems (India) Pvt. Ltd (ITA No.1961/Hyd/2011)(AY 2007-08) • Actis Advisers Pvt Ltd. (ITA No.5277/Del/2011 and ITA No. 958/Del/2012)(AY 2007-08), • Agnity India Technologies P. Ltd (ITA No.1204/HC/2011) • Market Tools Research Put Ltd (ITA No.1811/HYD/2012)(AY 2008-09) (xxiii) Wipro Limited (Segment) ('W .....

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Tools Research Put. Ltd. (ITA No.2066/Hyd/2011) (AY 2007-08) 9.28 Ld. AR submitted that the following comparable has unreliable financials:- (xxiv) Maple Esolutions Limited ('Maple') & Triton Corp Limited ('Triton') 9.29 Ld. AR submitted that this comparable company has unreliable financials. He submitted that the Directors of these companies were involved in fraud and hence their financial results were unreliable and the Director - the Rastogi family cheated the Government .....

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tremely volatile margins. Maple has shown 100% loss in financial year 2002-03 but all of a sudden it has shown profit of 37.38% in financial year 2004- 05. In financial year 2008-09, it again suffered losses with a negative margin of -65.23%. 9.32 Ld. AR relied on the decision of Actis Advisers Pvt Ltd - ITA No.5277/Del/2011 (AY: 2007-08) and ITA No. 958/Del/2012 (AY 2006-07) . 9.33 Ld. AR submitted that the following comparable has abnormal margins :- (xxv) IServices India Private Limited (' .....

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ITA No.06/PNJ/2013, TS-153 ITAT-2014(PAN)-TP), [2014- TII- 108-ITAT-PANAJI- TP), ITAT Panaji) - AY 2007-08 9.36 Ld. AR submitted that the following comparable has different business model :- (xxvi) Information Technologies Limited (Coral Hub Limited) ('Vishal' Outsourcing company) 9.37 Ld. AR submitted that this comparable company has different business model and took our attention to Exhibit 23. He submitted that Vishal Outsources most of its services to third party contractors which i .....

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parable customer to be comparable to the business model followed by the assessee as under :- Particulars Amount (in INR) Income from operations (A) 306,010,382 Personnel cost 7,027,631 Hiring charges 1,359,045 Employee cost (B) 8,386,676 Employee cost / sales (B/A) 2.74% 9.38 Ld. AR relied on the following case laws :- • Zavata India Private Limited [TS-156-ITAT-2013-CHD)-TP](AY 2007-08) • Avineno India Pvt. Ltd [TS-308-ITAT-2013-Hyd)-TP] AY 2007- 08) • Cognizant Technology Servic .....

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ed out to us that the aforesaid objections regarding filters, comparables, etc. had been taken before the DRP. However, the DRP has not addressed the issues and had only passed a cryptic order without discussing the merit of the matter. The ld. AR took our attention to pages 17 & 18 of the DRP order wherein the objection of the assessee and DRP observation are given as under :- 3.7 Without prejudice to assessee s other contentions, failing to apply the wages/ sales ratio filter to the ITES c .....

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g companies in the final comparables set for Benchmarking a low risk captive unit such as the Assessee (disregarding judicial pronouncements on the issue), thus demonstrating an intention to arrive at a pre-formulated opinion without complete and adequate application of mind with the singleminded intention of making an addition to the returned income of the Assessee; 3.9 Including certain companies that are not comparable to the Assessee in terms of functions performed assets employed and risks .....

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ration process to arrive at a set which is broadly comparable with reference to FAR to that of the assessee. In the circumstances, DRP finds' no reason to disturb the order of TPO on these grounds. Hence, objections are rejected. Ground No. 3.12 ignoring the business/ commercial reality that since the assessee (vis-a-vis both its ITES/ CSD services) is remunerated on an arm's length cost plus basis, i.e. it is compensated for all its operating costs plus a pre-agreed mark-up based on a b .....

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DRP has considered all the submissions and is of the view that the assessee cannot be compared to a risk free security (5 year zero coupon Govt. Bond). Further mechanical adjustment cannot be made to the margins of the comparables without knowing which risk was taken by the entity concerned and how its profitability was affected. Even methodology, whether ad hoc adjustment as in case of Sony India, CAPM as suggested by the assessee, or Sharpe Ratio (which is a measure of the excess return on ri .....

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necessary operating profit margins of the comparables and re-compute ALP accordingly, if required. Ground No. 3.14 disregarding judicial pronouncements in India in undertaking the TP adjustment. DRP/s Observation: The assessee has objected to disregarding judicial pronouncement in India in undertaking TP adjustments. 3.14.1 The assessee itself has contended that this is a general ground. On examination DRP finds that the persuasive value of various ITAT decisions has been acknowledged by the TPO .....

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