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Pr. Commissioner of Income Tax -1 Versus Actis Global Service Pvt. Ltd.

2017 (5) TMI 849 - DELHI HIGH COURT

TPA - TCS as not an appropriate comparable - Held that:- The Court finds merit in the contention of Mr. Kamal Sawhney, learned counsel for the Respondent, that as far as profile of the Assessee was concerned, it was not involved in software developme .....

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ppropriate comparable as far as determining of the arms length price of international transactions involving the Assessee is concerned. No substantial question of law - ITA 94/2017 - Dated:- 15-5-2017 - S. MURALIDHAR & CHANDER SHEKHAR JJ. Appella .....

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y the Revenue under Section 260A of the Income Tax Act, 1961 against the order dated 29th July, 2016 passed by the Income Tax Appellate Tribunal ( ITAT ) in ITA No. 6175/Del/2015 for the Assessment Year 2011-12. 3. Although the Revenue has urged a qu .....

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the exclusion of one comparable i.e., TCS E-Serve Ltd. ( TCS ). She explains that as regards the exclusion of two other comparables, namely, Infosys BPO Ltd. and E-Clerx Services Pvt. Ltd. ( ECS ), this Court has in its order dated 5th August, 2016 i .....

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r that TCS is involved both in transaction processing and technical services . The ITAT has referred to the decision of a Coordinate Bench of the ITAT in the case of Ameriprise India Pvt. Ltd. in ITA No. 7014/Del./2014 where, again, while determining .....

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venue's appeal i.e. ITA No. 461/2016. 6. Ms. Laxmi Gurung insisted that the only ground on which the ITAT proceeded to exclude TCS as comparable was that the segmental turnover data was not available. The ITAT observed that it was not known as to .....

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