TMI Blog2015 (10) TMI 2626X X X X Extracts X X X X X X X X Extracts X X X X ..... ng the Respondent Assessee - Held that:- One reason for exclusion of CGL was that it had outsourced its major activities whereas the Assessee was doing the business in-house. As far as ATL is concerned, it was noticed that there was merger of some other entity with it and, therefore, the said company could not be considered as a comparable. The submission of learned counsel for the Revenue is t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... egarding the ITAT having directed exclusion of two companies Cosmic Global Limited ( CGL ) and Accentia Technologies Limited ( ATL ) from the list of comparables for the purposes of determining the arm s length price ( ALP ) of the international transaction of provision of ITES involving the Respondent Assessee. 3. Having perused the impugned order of the ITAT, the Court finds that one reason ..... X X X X Extracts X X X X X X X X Extracts X X X X
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