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TMI Blog2016 (10) TMI 1035X X X X Extracts X X X X X X X X Extracts X X X X ..... te and onsite and that it receives the substantial revenues on account of onsite software financial development – the activity which the assessee does not carry out. ALso M/s Infosys Ltd. is that concern also owns brand intangibles- an advantage which the assessee does not possess.Lastly, the assessee is captive as opposed to status of M/s Infosys Ltd. M/s Persistent Systems Ltd- could not have be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Appellant : Mr. Rahul Chaudhary, Advocate For the Respondent : Mr. Sachit Jolly, Advocate along with Mr. Gautam Swarup, Advocate. ORDER The revenue in this appeal urges two substantial questions of law. The first pertains to exclusion of two comparables i.e. M/s Infosys Ltd. and M/s. Persistent Systems Ltd. The second question urged is the treatment of foreign exchange gain or loss in the tr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssess. Lastly, the assessee is captive as opposed to status of M/s Infosys Ltd. With respect to M/s Persistent Technologies, it is pointed out that in a previous order in ITA No. 279/2016 dated 04.05.2016 (Principle Commissioner of Income Tax vs. M/s Cashedge India Pvt. Ltd) held that having regard to the rules i.e. Rule 10 B to 10 E of Income Tax Rules, the data of M/s Persistent Systems Ltd- co ..... X X X X Extracts X X X X X X X X Extracts X X X X
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