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TMI Blog2016 (5) TMI 1348X X X X Extracts X X X X X X X X Extracts X X X X ..... s Wipro Technology Services goes, it was part of the Citi Group and was during the financial year in question acquired on 21.01.2009 by the Wipro Ltd. as a subsidiary. As a part of the arrangement, the existing contracts pertaining to the work of the Citi Group continued to be with the newly created entity, i.e., Wipro Technology Services. Equally importantly, is that there was no published segmented data as far as software development or its finances were concerned with respect to Wipro Technology Services. In these circumstances, the findings of the ITAT are purely factual and cannot be gone into as no substantial question of law arises for consideration. Refusal to give effect to the “Safe Harbour Rules” under Section 92 CA(3)- Held t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... echnology Services had to be included. This was objected to by the assessee which had approached the Dispute Resolution Panel ( DRP ); the latter by its order dated 14.11.2014 rejected the assessee s contentions. 3. The Income Tax Appellate Tribunal ( ITAT ) to which the assessee appealed excluded its companies holding that the inclusion of Persistent Systems Ltd. and Wipro Technology Services (WTS) was unwarranted. It, however, remitted the issue with respect to Zylog Systems Ltd. to ascertain the audited segmental data for ultimately deciding the comparable component in issue. So far as the question of fluctuation of foreign exchange was concerned, the ITAT ruled that the relevant provision, i.e., Safe Harbour Rules had not been noti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Rules, the data of the said firm, i.e., Persistent Systems Ltd. could not have been included. Likewise as far as the Wipro Technology Services goes, it was part of the Citi Group and was during the financial year in question acquired on 21.01.2009 by the Wipro Ltd. as a subsidiary. As a part of the arrangement, the existing contracts pertaining to the work of the Citi Group continued to be with the newly created entity, i.e., Wipro Technology Services. Equally importantly, is that there was no published segmented data as far as software development or its finances were concerned with respect to Wipro Technology Services. In these circumstances, the findings of the ITAT are purely factual and cannot be gone into as no substantial question of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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