TMI Blog2017 (10) TMI 943X X X X Extracts X X X X X X X X Extracts X X X X ..... easons for the exclusion and inclusion of comparables and therefore, no substantial question of law arises on this issue. As far as the issue concerning Section 14A apart from the tax effect being inconsequential, ITAT has relied on its orders for the earlier AYs. Consequently, no subsequent question of law arises on this aspect as well. - ITA 789/2017 - - - Dated:- 9-10-2017 - S. MURALIDHAR ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... filing Appeal before this Hon'ble Court... 3. The Supreme Court in Postmaster General v. Living Media India Limited (2012) 3 SCC 563 observed as under: In our view, it is the right time to inform all the government bodies, their agencies and instrumentalities that unless they have reasonable and acceptable explanation for the delay and there was bona fide effort, there is no need ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 9th June 2016 passed by the Income Tax Appellate Tribunal ( ITAT ) in ITA No. 481/Del./2014 for the Assessment Year ( AY ) 2009-10. 7. The first question of law sought to be urged by the Revenue concerns the exclusion and inclusion of comparables for the purpose of determination of arm s length price of the international transactions entered into by the Assessee with its associated enterprises ..... X X X X Extracts X X X X X X X X Extracts X X X X
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