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TMI Blog2014 (7) TMI 1238X X X X Extracts X X X X X X X X Extracts X X X X ..... able cases, the learned Tribunal in paragraph 15 of the judgment and order has held that the Coordinate Benches have already decided that these companies are not to be selected for comparable cases for various reasons. Similarly, on the question of software segmentation, the learned Tribunal in paragraph 17 has followed various judgments of the Coordinate Benches. No substantial question of law. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the circumstances of the case, the Tribunal was justified in rejecting comparable companies on the ground of functional difference when the tax payer itself did not consider the verticals and horizontals of the Software/ITES Sector? 3. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in rejecting comparable companies on the ground of supernormal profits w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Tribunal was justified in admitting the additional grounds and thereby allowing the tax payer to raise contentions on the comparables selected by itself in the TP study? 7. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in holding that communication expenses should be excluded from both export turnover as well as total turnover for the purpose ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Therefore, we find that the Tribunal has followed the consistent decisions of not only the Coordinate Benches of the Tribunal but that of the Special Bench also. It is not the case of the appellant that the aforesaid decisions are subject matter of challenge before any forum or are upset. On the question of comparable cases, the learned Tribunal in paragraph 15 of the judgment and order has hel ..... X X X X Extracts X X X X X X X X Extracts X X X X
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