TMI Blog2018 (2) TMI 2063X X X X Extracts X X X X X X X X Extracts X X X X ..... in knowledge management systems and international transactions/activities in respect of one of the services rendered to its associated enterprises i.e. (AE). Notional interest attributed to the assessee and for which adjustment was made by the TPO, was finally affirmed by the ITAT - This Court has considered the submissions of the parties and is of the opinion that having regard to the cons ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... MR. JUSTICE A. K. CHAWLA For the Appellant : Mr. Porus Kaka, Sr. Advocate with Mr. Divesh Chawla Mr. Harpreet Singh Ajmani, Advocates , Mr. Divesh Chawla Mr. Harpreet Singh Ajmani, Advocates For the Respondent : Mr. Rahul Chaudhary with Ms. Vibhooti Malhotra, Advocate O R D E R ITA 461/2017 ITA 526/2017 Admit. The following question of law arises- Did the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ay, if ITA 461/2017 connected matters deem necessary, file a report in this regard. All the rights of the parties are reserved. Judgment reserved. ITA 590/2017 82/2018 The following question of law arises : Did the ITAT fall into an error in excluding the relative comparables which were held to be irrelevant for the purpose of ALP determination in the circumstances of the c ..... X X X X Extracts X X X X X X X X Extracts X X X X
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