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The Pr. Commissioner of Income Tax -9 Versus WSP Consultants India Pvt. Ltd.

2017 (11) TMI 464 - DELHI HIGH COURT

TPA - selection of comparable - selection criteria - Held that:- This Court is of the opinion that the rationale that Ashok Leyland was deriving major part of its revenue from wind energy segment and that there was an extraordinary event of merger an .....

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on 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 consideration or excluded relevant factors in the ALP determination that .....

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r Bhatia, Adv. For the Respondent: Mr. Kamal Sawhney and Mr. Shikhar Garg and Mr. Prashant Maherchandani, Advs S. RAVINDRA BHAT, J. (OPEN COURT) CM No. 39550/2017 (condonation of delay) For the reasons stated in the application, the delay in filing t .....

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ary 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 .....

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entity which engages itself in these and other related activities. 4. The TPO, who had to consider the report filed by the assessee for ALP determination, took into consideration 16 comparables and derived the ALP bringing to tax a sum of ₹ 6, .....

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led an appeal challenging inclusion of 3 comparables i.e. Ashok Leyland Projects Services Ltd., Kitco Ltd. and Mitcon Consultancy & Engineering Services Ltd., the ITAT upheld the assessee s contentions. 6. As far as the first comparable - Ashok L .....

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ok Leyland Wind Project Services Ltd. and another company which presented a clear possibility of differential advantage. 7. With respect to M/s Kitco Ltd. the Tribunal held that it was a substantial government undertaking and prominent business was f .....

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vities such as training and engaging in laboratories and research etc. 8. We have heard the counsel for the Revenue who urges that the rationale for exclusion of three comparables which were high income entities is unpersuasive. 9. This Court is of t .....

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