TMI Blog2018 (1) TMI 1548X X X X Extracts X X X X X X X X Extracts X X X X ..... al Information Technologies Ltd both of which transact entirely different business i.e. Knowledge Processing Outsourcing (KPO), was justified. The assessee concerns itself with the broader range of Information Technology (IT) enabled Back Office Support Services. In the other two cases of M/s Infosys BPO and Wipro BPO Ltd., the ITAT again, in the opinion of this Court, quite correctly held that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y Accentia Technology Pvt. Ltd. for A.Y. 2007-08 had any effect on its finance or profitability in the circumstances of the case. (2) Did the ITAT err in excluding the reliance placed by the TPO upon information collected by him under Section 133(6) of the Act, having regard to Section 92CA(7) read with Section 92D(3) of the Act. - ITA 912/2017 And CM APPL. 38877/2017 - - - Dated:- 3-1-2018 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... parables used for the ALP determination. The Revenue s appeal in the present case for A.Y. 2007-08 is confined to the exclusion (which it characterised as erroneous) of seven comparables. This Court is of the opinion that the exclusion of five comparables in the present case by the ITAT is on sound basis. The ITAT quite correctly found that the exclusion of Eclerx Services Ltd and Vishal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cise. In these circumstances, out of the seven comparables, the five are to be ruled out and no question of law arises in this case. The Court has considered the submissions with respect to the Accentia Technology Pvt. Ltd. and Bodhtree Consulting Ltd. The Court admits the following questions of law:- (1) Did the ITAT err in its consideration as to whether the amalgamation und ..... X X X X Extracts X X X X X X X X Extracts X X X X
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