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M/s. NTT DATA Global Delivery Services Ltd. (formerly known as Keane International (India) Pvt. Ltd.) Versus Asst. Commissioner of Income-tax, Circle 11 (5) , Bangalore and Deputy Commissioner of Income-tax, Circle 11 (5) , Bangalore Versus M/s. Keane International (India) Pvt. Ltd.

2016 (4) TMI 1221 - ITAT BANGALORE

TPA - comparable selection - Held that:- Companies into software development need to selected as final comparable similar as that to assessee. Companies need to be deselected on the basis of functional dissimilarities with that of assessee which is involved in providing software services. - The event of merger itself cannot a factor for exclusion of the company from the list of comparables also when the malgamated company is also engaged in the same business as that of the assessee-company. .....

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umstances of the case and find that the receipts on account of recruitment fees, interest and miscellaneous activity do not have any nexus, whatsoever with the activity of export of computer software. As such they cannot be treated as part of business profits in the computation of deduction u/s/10A - Decided against assessee - IT(TP)A No.1487/Bang/2013, IT(TP)A No.1496/Bang/2013 - Dated:- 6-4-2016 - SHRI VIJAY PAL RAO, JUDICIAL MEMBER and SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER For The Assessee .....

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s of rendering software development services to its holding company as well as other group companies. The main areas of specialization of the assessee-company are real-time technology for network systems, wireless applications, mobile computing and bar code scanning. Later, during financial year 2009-10, the Hon ble High Court of Karnataka and Delhi approved the merger of assessee-company with Kene India w.e.f. 1/4/2008. However, Keane India Ltd., has now been renamed as NTT DATA Global Delivery .....

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saction entered with its AE to be at arm s length price [ALP]. The assessee-company had also submitted transfer pricing study report adopting the operating profit to total cost (OP/TC) as a profit level indicator for the transfer pricing study. The assessee-company applied Transactional Net Margin Method [TNMM] which was considered to be the most appropriate method for purposes of bench marking the international transactions. The assessee-company s profit margin was computed at 16.9% and the ass .....

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sessee-company had chosen the following 18 entities as comparables whose average profit margin was computed at 9.73%: Sl. No. Comparable Weighted Average Margin 1 ASM Technologies (consolidated result) -1.09% 2 Astro Bio System Ltd 11.35% 3 Blue Star (consolidated result) 21.29% 4 Computech International 4.20% 5 Cressanda Solutions Ltd (consolidated result) 1.59% 6 Geometric Software Solutions 32.53% 7 Goldstone Technolgies Ltd 7.23% 8 Helios & Matheson information (consolidated result) 23.1 .....

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cer (TPO). The TPO, by an order dated 15/09/2008 passed u/s 92CA(3) of the IT Act, 1961 computed the transfer pricing adjustment at ₹ 14,87,14,525/-. The TPO accepted the TNMM adopted by the assessee-company but rejected the transfer pricing study report. The TPO proceeded to identify a different set of comparable entities for the purpose of determining the ALP. While doing so, the ld. TPO had applied the following filters: Use of current year data (i.e. FY 2004-05) only; Turnover filter i .....

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eater than 75% of their operating revenue. The TPO rejected 15 of the comparables selected by the assessee-company in the TP study and introduced 14 new companies and finally selected the following comparables: SI No. Comparable TP Study Margin (Unadjusted) 1. Bodhtree Consulting Limited 24.85 2. Lanco Giobal Systems Limited 13.65 3. Exensys Software Solutions Limited 70.68 4. Sankhya Infotech Limited 27.39 5. Sasken Network Systems Limited 16.64 6. Four Soft Limited 22.98 7. Thirdware Solution .....

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.59 Working Capital Adjustment 1.24 Adjusted Arithmetic Mean 25.35 The TPO computed average profit margin of the comparables finally selected at 26.59% and after giving working capital adjustment of 1.24%, the adjusted arithmetical mean PLI was determined at 25.35%. On the above said basis, the TPO computed the transfer pricing adjustment as follows: Arms length price @ 125.35% of operating cost …. Rs.211,45,86,091/- Price received including reimbursement ₹ 196,58,71,566/- Shortfall .....

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in the nature of interest income and miscellaneous income to be excluded from the profits of the business. The AO also held that the communication expenses be reduced from the export turnover for the purpose of computing the deduction u/s 10A of the IT Act, 1961. 6. Being aggrieved, an appeal was preferred before the ld.CIT(A)-IV, Bangalore. It was contended before the ld.CIT(A), inter alia, that the very reference made by the AO to TPO is invalid in law. The ld.CIT(A), after upholding the valid .....

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ilarity. The ld.CIT(A) had upheld the inclusion of Thirdware Solutions Ltd., by holding that no company can be excluded on the ground of abnormal profits or losses unless the assessee demonstrates and establishes that abnormal profits were earned wholly on account of some extraordinary event taking place. In this connection, he placed reliance on the decision of Bangalore bench of Tribunal in the case of TrilogyEBusiness Services Pvt. Ltd. reported in 29 taxmann.com 310. The ld.CIT(A) however, u .....

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us with the activity of export of software and therefore held that they cannot be treated as part of business profits for the purpose of computing deduction u/s 10A of the Act. 6.2 As regards telecommunication expenses incurred for delivery of software, held that the same should be reduced from the export turnover as well as the total turnover for the purpose of computing deduction u/s 10A of the Act placing reliance on the decision of the jurisdictional High Court in the case of CIT vs. Tata El .....

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alysis undertaken by the Appellant in accordance with the provisions of the Act read with the Income Tax Rules, 1962 ("the Rules"), for the determination of the arm's length price in connection with the impugned international transaction and holding that the Appellant's international transaction is not at arm's length; 2. the learned CIT(A) has erred in upholding the action of the learned TPO in obtaining information which was not available in public domain by exercising po .....

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in ignoring the consistency in sharing methodology and similarity of transaction and their acceptance in the earlier and subsequent years and has erred in holding that the determination of the arm's length price by the Assessee accepted by the Revenue authorities in any earlier year cannot operate as res-judicata for any other assessment year; 5. the learned CIT(A) has erred in upholding the action of the learned AO/TPO in conducting a fresh economic analysis considering only FY 2004- 05 fin .....

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any cogent reasons: a) the learned CIT(A) has erred in upholding the action of the learned AO/TPO in applying export revenues greater than 25% of total revenues filter as a comparability criterion in the search strategy to identify comparable companies; b) the learned CIT(A) has erred in upholding the action of the learned AO/TPO in applying diminishing revenue filter as a comparability criterion in the search strategy to identify comparable companies, i.e. rejecting companies as having economi .....

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reater than 75% of the total revenues filter as a comparability criterion in the search strategy to identify comparable companies; 7. the learned CIT(A) has erred in upholding the action of the learned AO/TPO of applying a turnover filter of less than 1 crore; 8. the learned CIT(A) has erred in not adjudicating on the Appellant's contentions against 11 specific companies accepted by learned TPO which are to be rejected on account of functional dissimilarity and have instead summarily directe .....

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he comparable companies; instead held such ground to be general in nature; 11.the learned CIT(A) has erred in not adjudicating the action of the learned TPO in adding the amount of the reimbursements of expenses incurred by the Appellant on behalf of its AEs to the operating cost for the purpose of determining ALP under the Transactional Net Margin Method; instead held such ground to be general in nature; 12.the learned CIT(A) has erred in holding that where an adjustment to the differences in w .....

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ection 10A of the Act should not be eligible for recruitment fees as such remarks were made without verifying the nature of services undertaken by the Appellant in this regard; 15.The learned CIT(A) has erred in law and on facts in not appreciating that the recruitment fees is eligible for deduction under section 10A of the Act since it is covered within the notified information technology enabled services constituting computer software; 16.The learned CIT(A) has erred in law and on facts in ign .....

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s income which form part of the business income of the Appellant. 8. Ground Nos.1 to 7 are not pressed during the course of hearing and the same are dismissed. 9. Ground No.8 challenges the direction of the ld.CIT(A) remitting the ground relating to functional dissimilarities of comparables to the TPO without rendering any specific direction. 9.1 The learned AR of the assessee-company submitted that the comparables chosen by the TPO viz., Bodhtree Consulting, Exensys Software Solutions, Flextron .....

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can be seen from the above analysis, this company has erratic margins and growth over the years. The margins of Bodhtree are consistently changing. This reflects that the revenue recognition policy followed by Bodhtree is not proper and is resulting in consistent change in margins. Further, the growth rate over the years is also fluctuating to extremes. Further, growth in revenues is not supported by growth in expenses. In some cases, expense growth is higher than the revenue growth. Also salary .....

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Kodiak Networks India Pvt. Ltd (supra) it is clear that the Tribunal has followed its earlier decision in Mindtech India Ltd. vs. DCIT in ITA No.70/B/2014 dated 21/8/2014 wherein it was held that on account of change in method of accounting of the revenue recognition, there were fluctuations in the profit margins of the company. The decision in Mindtech India Ltd. is in relation to assessment year 2009-10 and the decision was based on the reasoning that there were fluctuations in the margins of .....

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xcluded from the list of comparables on the ground of wide fluctuations in the margins of the company, without going into the issue whether wide fluctuation would have any impact on the comparability. 9.3 However, the assessee-company s contention before the TPO as well as before us is that this company is engaged in the sale of IT products as well as software development services and no segment details were available. It was further submitted that this company had related party transaction. 9.4 .....

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the submissions of the assessee-company on this score cannot be accepted as devoid of any substance. 9.5 In the result, we uphold the action of TPO in including this company in the list of comparables. 10. As regards Exensys Software Solutions Ltd., this comparable was selected by the TPO. The assessee-company objected to the inclusion of this company in the list of comparables on the ground that it is engaged in the software products and had related party transactions. This contention was rebu .....

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ITO vs. Sunquest Information Systems (India) Pvt. Ltd. in IT(TP)A No.1302/Bang/2011 dated 11/6/2015 wherein this Tribunal, vide para.14 of its order, had directed the exclusion of this company from the list of comparables on the ground that the company is dealing in the software products and earned abnormal profits on account of amalgamation etc. 10.2 We perused the annual report of this company paced at pages 1097 to 1129 of the paper book. From perusal of page 1104 of the paper book it is cle .....

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of the assessee-company that the amalgamating company is functionally dissimilar. In fact, the notes to accounts states that this amalgamated company i.e. Holool India Ltd. is also engaged in the same business as that of the assessee-company. Therefore, the event of merger itself cannot a factor for exclusion of this company from the list of comparables, as held by the Mumbai bench of the Tribunal in the case of Wills Processing Services (India) (P) Ltd. vs. DCIT (32 taxmann.com 18) (Mum). Hence .....

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at the related party transactions are less than 25% and the segmental details are made available. It is further noticed that the revenue from the services constitutes more than 85%. Therefore, it can be treated as a software development services company as it passes through revenue filters adopted by TPO. During the course of hearing before us, the ld.AR of the assessee-company had relied on the order of the co-ordinate bench of Tribunal in the case of ITO vs. Sunquest Information Systems (India .....

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oduct sales also and therefore, it is functionally dissimilar. But from the order of the TPO as well as the financial results of the company, it is clear that 85% of the revenue of the company is derived from software services. Therefore, it can be safely classified as a software development services. Therefore, this company cannot be excluded from the list of comparables. Geometric Software Solutions: 12. This Company was selected by the assessee-company and accepted by the TPO as it satisfied .....

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find that this company was not considered in the said decision. Therefore, the reliance placed by the learned AR of the assessee-company on this decision is misplaced. Therefore, we do not find any reason to exclude this company from the list of comparables. Sankhya Infotech: 13. This comparable was selected by the TPO. The assesseecompany objected to the inclusion of this company as a comparable on the ground that personnel cost (salary) is less than 15% of the sales, which is less than the ind .....

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rdinate bench of Tribunal in the case of Sunquest Information Systems (India) Pvt. Ltd. (cited supra) on this comparable reveals that the co-ordinate bench had followed the decision of Delhi Tribunal in the case of ITO vs. Colt Technology Services India Pvt.Ltd. (in ITA No.609/Del/2011 dt.23/10/2012 and no reasons were given by the Tribunal as to why this company cannot be considered as a comparable. Therefore, we are unable to discern any ratio in the decision cited supra. Thus, the learned AR .....

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Sons Ltd. In other words, the assessee-company s contention is that it has related party transactions of more than 25%. This contention of the assessee-company was rebutted by the TPO by holding that the revenue from Tata Consultancy Services was only ₹ 8.41 crores out of total revenue of ₹ 146.46 crores which amounts to 5.7% of the total revenue. Thus the contention of the assessee-company that it had related party transactions of more than 25% was not accepted by the TPO. 14.1 Bef .....

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services and visual computing labs. Learned AR of the assessee-company placed reliance on the decision of the Tribunal in the case of Sunquest Information Systems (India) Pvt. Ltd. (cited supra) and Textron Global Technology Centre Pvt. Ltd. (cited supra). 14.2 We heard the rival submissions and perused material on record. The co-ordinate bench of Tribunal in the case of Sunquest Information Systems (India) Pvt. Ltd. (cited supra) held (vide paras. 28 and 29 of the order) that it is not compara .....

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e development services segment itself comprises of three subservices namely (a) product design services (b)design engineering services and (c) visual computing labs. It was submitted that these services are not akin to assessee software services and segmental information of only product design services could have been accepted by the TPO as a comparable but not the entire software development service. Since company s operations are functionally different as such, the same is not comparable. Furt .....

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rvice Provider and that it cannot be compared with any other software development company. It was submitted that because of the specialisation and also because of diverse nature of its business, it is very difficult to scale-up the operations of Tata Elxsi Limited. In view of this, Tata Elxsi Limited has informed that it is not fair to use its financial numbers to compare it with any other company. The communication dated 25th August, 2009 to the TPO is placed before us. As this communication wa .....

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cisions of the Coordinate Bench, prima facie, we are of the view that Elxsi Limited is functionally different and has incomparable size to that of the assessee. Further, we are unable to verify whether the segmental profits adopted by the TPO pertain to entire software development services or pertain to limited service akin to assessee services. Since, these aspects are not clear from the data furnished before us, we direct the TPO to examine and in case, the segmental profits of a particular se .....

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subsequent ruling in the case of Invensys Development Centre (India) Pvt.Ltd., ITA No.1256/Hyd/2010 order dated 28.2.2014, held that TATA Elxsi is not functionally comparable with that of a software development service provider such as the Assessee. 14.3 We do not find any reason to differ with the decision of the co-ordinate bench in the above cases. Accordingly, we hold that this company cannot be held to be comparable with that of the assessee-company on functional dissimilarities. In our op .....

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revenue is from software development services; this can be considered as a comparable. 15.1 Before us, learned AR of the assessee-company submitted that this company cannot be considered as comparable in the light of the decisions of the co-ordinate bench in the case (i) the Sunquest Information Systems (India) Pvt. Ltd.(cited supra); (ii) Textron Global Technology Centre Pvt. Ltd(cited supra) and (iii) Colt Technology Services India Pvt.Ltd. (cited supra). 15.2 We heard the rival submissions a .....

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segregate profitability from provision of software development services and from sale of software licences. These information were supported by the annual report for Financial year 2004- 05 of the said company. In its annual report a generic disclosure was made that the company is involved in trading of software and provision of IT services. Schedule 14 of the Financial statement of the said company provide information on details of purchases as per which the total purchase cost incurred by the .....

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ded the finding as under: 26. As far as Thirdware Software Solution Limited is concerned, we find from the information furnished by the said company that though the said company is also into product development, there are no software products that the company invoiced during the relevant financial year and the financial results are in respect of services only. Thus, it is clear that there is no sale of software products during the year but the said company might have incurred expenditure towards .....

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ough the said company is also into product development, there are no software products that the company invoiced during the relevant financial year and the financial results are in respect of services only. Thus, it is clear that there is no sale of software products during the year but the said company might have incurred expenditure towards the development of the software products. 26. As far as Flextronics Software Limited is concerned, we find that at page 90 of his Order, the TPO has also o .....

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lopment services and software product activity cannot be said to be correct and reasonable. Wherever, the Assessing Officer/TPO cannot make suitable adjustment to the financial results of the comparable companies with the assessee company to bring them on par with the assessee, these companies are to be excluded from the list of comparables. Therefore, we direct the Assessing Officer/TPO to exclude these three companies from the list of comparables. 15.3 The decision in the case of Sunquest Info .....

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service provider. Hence, we direct the TPO/AO to delete this company from the list of comparables. 16. The other comparables were either accepted by the assessee-company or not pressed during the course of hearing. Thus, the grounds of appeal Nos.8 to 9 are disposed of. 17. Ground Nos. 9 to 13 are not pressed and hence dismissed as such. 18. Ground Nos.14 & 15 challenge denial of relief u/s 10A in respect of recruitment fees earned. The ld.CIT(A) upheld the action of the AO in denying deduct .....

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recruitment fees, interest and miscellaneous activity do not have any nexus, whatsoever with the activity of export of computer software. As such they cannot be treated as part of business profits in the computation of deduction u/s/10A. Hence, I uphold the action of the AO. We do not find any reason to differ with the reasoning of the ld.CIT(A). Hence, the grounds of appeal in this regard are dismissed. 19. In the result, the appeal filed by the assessee-company is partly allowed. ITA No.1487/ .....

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ase depends on assessee specific FAR analysis. 3) The Ld. CIT(A) erred in relying on the decisions of the ITAT including those of other benches of ITAT, without appreciating the specific facts brought on record by the TPO in the case of the assessee and the similar issue has been agitated before the Karnataka High Court in other cases. 4) The Learned CIT(A) erred in directing the TPO to exclude functionally dissimilar companies subject to the guidelines laid down by of the Mumbai Bench of the Ho .....

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not available in respect of units 1,2,3 and 4 as the production commenced in these units much before obtaining the license for the bonded warehouse by placing reliance on the orders of the ITAT for the A.Y 2001-021 2003- 041 2004-05, 2006-07 and 2007-08 in the assessees own case without appreciating the fact that the decision of the ITAT has not been accepted by the department and appeals u/s 260A have been filed before the Hon'ble High Court. 6) The CIT(A) erred in directing the AO to foll .....

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s decision in the case of Tata Elxsi Limited 349 ITR 98 has not been accepted by the department and an appeal has been filed before the Hon'ble Supreme Court. 8) For these and such other grounds that may be urged at the time of hearing, it is humbly prayed that the order of the CIT(A) be reversed in so far the above issue is concerned and that of the A.O. be restored. 9) The appellant craves leave to add, to alter, to amend or to delete any of the grounds that may be urged at the time of hea .....

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he companies which are not functionally similar cannot be considered as comparable. Therefore, we do not find any infirmity in the direction of the ld.CIT(A). 23. The revenue is challenging direction of the CIT(A) to exclude the following companies from the list of comparables on the ground that the turnover of the above companies is more than ₹ 200 crores relying on the decision in the case of Genesis Integrating Systems (India) Pvt. Ltd. vs. DCIT (20 taxmann.com 715(Bang.): i. Infosys ii .....

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actions by drawing the attention of the assesseecompany to the annual reports of those companies. 24. We now deal with each of these companies. Before adverting to the comparables, it is worth mentioning here that there are divergent decisions of the Tribunal whether high turnover is a relevant for accepting/rejecting a comparable in the case of a service company. For example, the Mumbai bench of the Tribunal in the case of Capgemini India Pvt Ltd. Vs. ACIT (TS 45 ITAT 2013(Mum)(TP) held that th .....

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the area of software development and it assumed all risks leading to higher profit. On the other hand, the assessee-company is a captive unit of its parent company in US and assumed only limited risk. In the similar circumstances, the Hon ble Delhi High Court in the case of CIT vs. Agnity India Technologies P.Ltd. held that Infosys cannot be treated as a comparable. Even several co-ordinate benches of Tribunal held that Infosys Ltd. cannot be considered as comparable as it is having high intangi .....

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fotech has related party transaction of only 8%. We do not see any other reason to exclude this company from the list of comparable. Therefore, we uphold the action the TPO in including this company in the list of comparables. 24.2 As regards Satyam Computer Systems, there is no dispute that this company is functionally similar. The only objection of the assessee-company for including this company is high turnover. As held by us above, turnover is not a relevant criteria in the service industry .....

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ecial Bench of Tribunal, in eh case of Quartz systems has held that at any stage of proceedings, either before TPO or appellate proceedings, a new comparable can always be considered. 26. Ground No.5 challenges the direction of the ld.CIT(A) allowing the benefit of deduction u/s 10A of the Act to the assessee-company. The issue in appeal is squarely covered in favour of the assessee-company by the decision of the Hon ble High Court of Karnataka in the assessee s own case in ITA No.403 of 2008 da .....

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