2017 (4) TMI 184

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..... Advocates JUDGMENT S. J. Vazifdar, CJ. 1. This is an appeal against the order of the Tribunal excluding from consideration two comparables, namely, Nucleus Netsoft and GIS (India) Limited and Vishal Information Technologies Limited. The matter pertains to the assessment year 2006-07. 2. The appellant contends that the following substantial question of law arises in the appeal : "Whether in .....

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..... ny, M/s. Nucleus Netsoft and GIS India Ltd., had its name changed to that of the transferor company. 4. It is not necessary to go into the question of the effect of the merger as the order of the Tribunal can be upheld on the ground that both the companies are not appropriate comparables as a major part of their business is outsourced, whereas the major part of the respondent-assessee's busin .....

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..... e same is erroneous much less perverse. The exclusion of Vishal Information Technologies Limited is, therefore, justified. 6. The only contention regarding the exclusion of Nucleus Netsoft and GIS (India) Limited is that there is no reasoning. This, however, is not even a ground taken in the appeal filed before us. In any event, we perused the 22nd annual report for the year 2005-06 of Nucleus Ne .....

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