TMI Blog2017 (11) TMI 464X X X X Extracts X X X X X X X X Extracts X X X X ..... deriving income from government entity and Mitcon Consultancy & Engineering Services Ltd, is deriving less than 75% revenue from consultancy services, is a reasonable basis for their exclusion. Any inclusion or exclusion of comparables perse cannot be treated as a question of law unless it is demonstrated to the Court that the Tribunal or any other lower authority took into account irrelevant ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion, of the assessee s income, is erroneous. 2. The assessee is subsidiary of Cyprus based company and is a global business provider involved in design, engineering, management consultancy services across the built and nature environment worldwide. It provides the services to transform the built environment and restore the natural environment and its expertise in the relative fields. 3. T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... con Consultancy Engineering Services Ltd., the ITAT upheld the assessee s contentions. 6. As far as the first comparable - Ashok Leyland Projects Services Ltd. is concerned, the ITAT was of the opinion that the major part of the Revenue derived was from wind energy segment and secondly that during the relevant year there was an extraordinary event being merger of ALPSL with Ashok Leyland Wind ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g major part of its revenue from wind energy segment and that there was an extraordinary event of merger and likewise M/s Kitco Ltd. deriving income from government entity and Mitcon Consultancy Engineering Services Ltd, is deriving less than 75% revenue from consultancy services, is a reasonable basis for their exclusion. 10. Any inclusion or exclusion of comparables per se cannot be treated ..... X X X X Extracts X X X X X X X X Extracts X X X X
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