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TMI Blog2021 (1) TMI 73X X X X Extracts X X X X X X X X Extracts X X X X ..... RDER B.R. Baskaran, Member (A) 1. The assessee has filed this appeal challenging the assessment order dated 29-10-2018 passed by the assessing officer for assessment year 2014-15 u/s. 143(3) r.w.s. 144C of the Act in pursuance of directions given by Ld Dispute Resolution Panel (DRP). 2. This appeal was earlier disposed of by the co-ordinate bench on 18-12-2019. Thereafter, the assessee filed a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2/Bang/2016 dated 28-05-2019) and has held it to be a good comparable for a captive software development service company. 4. We heard Ld D.R and perused the record. We notice that the co-ordinate bench has held in the case of LG Soft India P. Ltd. (supra) that M/s. I2T2 India Limited is a good comparable for a captive software development company. The relevant observations made by the co-ordinate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee cannot be held responsible to prove a fact relating to a third party, which may or may not exist. We notice from the Auditors Report of M/s. T2T2 India Ltd. that the auditor in para 5(b) of Annexure to the Auditor's report has mentioned as under:- "There are no transactions that are made at prices exceeding Rs. 5 lakhs in respect of any party who is covered under section 301 of the Act du ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... TPO/AO for inclusion of the I2T2 India Ltd. as a comparable company. 6. In ground no. 8, the grievance of the assessee is that the AO has not granted credit of correct amount of advance tax, self assessment tax and TDS amounts. In ground no. 9, the grievance of the assessee is that the AO has not granted credit of correct amount of Minimum Alternative Tax (MAT) u/s. 115JAA of the Act. 7. We noti ..... X X X X Extracts X X X X X X X X Extracts X X X X
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