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TMI Blog2023 (1) TMI 1089X X X X Extracts X X X X X X X X Extracts X X X X ..... nkar i/b Mint & Confreres. P.C. This is an appeal under Section 260A of the Income Tax Act, 1961 ("the Act") against the Order of the Tribunal dated 11 January 2017 in Income Tax Appeals ITA(TP) NO.927/Mum/20167 and ITA(TP) NO.902/Mum/2016 for the assessment year 2011-12. 2. We have heard learned Counsel for the parties. 3. The Appeal is admitted on the following substantial questions of law : ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ITeS, even though segmental results show that the Company had persistent loss in the comparable segment and comparable segment failed the turnover filter of Rs.1 Crore? 3. Whether, on the facts and in the circumstances of the case and in law, the ITAT is justified in directing the AO to include M/s R Systems Ltd (RSL) as a comparable for ITeS although the Company has different year ending than t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the ITAT is justified in directing the AO to include M/s ICRA Management Consulting Services Ltd (ICRA), engaged in rendering Managing Consultancy Services, as comparable for benchmarking of ALP of investment advisory services ? C. Whether, on the facts and in the circumstances of the case and in law, the Tribunal is justified in directing the AO to include IDC India Ltd. (IDCL), a Company engag ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t of valid comparables. In regard to ICRA Management Consultancy Services (ICRA) and IDC India Limited (IDCL), DRP held that the functions performed by ICRA were different from the functions carried out by the Petitioner and ICRA was providing consultancy services and was engaged in management consultancy and therefore, could not be considered as comparable. 6. As regards IDCL, it was held that t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed and established as merchant banker. This view has also been taken in Principal Commissioner of Income Tax Vs. NVP Venture Capital India (P) Ltd. (2018) 100 taxmann.com3 (Bombay). 8. Be that as it may, the questions A, B and C as suggested do not give rise to any substantial questions of law. 9. Registry is directed to communicate copy of this Order to the Tribunal. This would enable the Tribu ..... X X X X Extracts X X X X X X X X Extracts X X X X
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