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2019 (5) TMI 1063

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..... self earlier in the list of comparables submitted by it, later it was noticed that GICL was engaged in diversified operations providing high-end and complex services such as GIS Consulting, 3D Mapping, Navigation Maps, Remote sensoring, etc. On the other hand the Assessee was engaged only in providing back office IT enabled services. GICL operated as a full-fledged risk taking entrepreneur whereas .....

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..... S.S. Tomar, Advocates O R D E R CM APPL. 22485/2019 (Delay of 145 days in refiling appeal) 1. For the reasons stated in the application, the delay in re-filing the appeal is condoned. The application is disposed of. ITA 487/2019 2. This appeal by the Revenue is directed against an order dated 18th June, 2018 passed by the Income-tax Appellate Tribunal (ITAT) in ITA No. 2559/Del/2014 for Assessment .....

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..... that the Assessee had selected TNMM for computation of Arm s Length Price (ALP), the matter was referred to the Transfer Pricing Officer (TPO). By the order dated 14th December, 2012 the TPO did not agree with the various filters used by the Assessee for the transfer pricing study. The TPO used some more filters and required the Assessee to submit the comparables on the basis of the new filters. 6 .....

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..... rables. A final assessment order was then passed under Section 143(3) of the Act by the AO deleting the earlier proposed transfer pricing adjustment. 8. The Revenue being aggrieved by the said order of the AO, filed an appeal before the ITAT. By the impugned order, the ITAT upheld the order of the AO. Although GICL had been included by the Assessee itself earlier in the list of comparables submitt .....

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