2018 (4) TMI 1840

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..... t the entity (Wipro Technology) had undergone restructuring which had a significant impact upon its return and profitability - HELD THAT:- This Court is of the opinion that the ITAT conclusions were reasonable and justified. A strong brand presence and unusual events such as amalgamation, merger, etc. which can have a miserable impact and are discerning from the record, are reasonable grounds fo .....

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..... e benefit of strong brand presence. It is also found that the entity (Wipro Technology) had undergone restructuring which had a significant impact upon its return and profitability. Learned counsel sought to rely upon the decision of this Court in Chryscapital Investment Advisors (India) Pvt. Ltd. v. Deputy Commissioner of Income Tax ( 2015) 376 ITR 183 Del. This Court is of the opinion that the I .....

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