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TMI Blog2018 (4) TMI 1536X X X X Extracts X X X X X X X X Extracts X X X X ..... from final list. - Income Tax Appeal No. 1226 of 2015 - - - Dated:- 23-4-2018 - M.S. SANKLECHA SANDEEP K. SHINDE, JJ. Mr. Suresh Kumar, for the Appellant. Mr. Percy Pardiwala Senior Advocate a/w Mr. Nitesh Joshi i/b Mr. Atul Jasani, for the Respondent. P.C. : This Appeal under Section 260-A of the Income Tax Act, 1961 (the Act), challenges the order dated 11 February 2015 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ties mentioned at nos.(i) to (iv) above are not Comparables to the Respondent. This by following the decision of its Co-ordinate Bench in PTC Software (I) Pvt.Ltd. (India) Private Limited vs. DCIT vide ITA No.336/PN/2014 , decided on 31 October 2014. 4. Mr. Suresh Kumar learned counsel appearing for the Revenue very fairly pointed out that being aggrieved by the decision of the Tribunal in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lutions Limited, is concerned the impugned order of the Tribunal has excluded it from the list of comparables. This by following its decision in DCIT vs M/s Wills Processing Services (India) Pvt. Ltd. vide ITA No.2152/Mum/2014 dated 10.10.2014 . Mr. Suresh Kumar learned counsel appearing for the Revenue states that inspite of his best efforts, the Revenue is unable to instruct him whether or no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s Court recorded the fact that M/s Crossdomain Solutions Ltd. was engaged in distinct activities such as payroll activity, 'Knowledge Process Outsourcing'(KPO) service, development of products and routine IT services. Thus, it was found not comparable with an entity which was rendering E-learning services. In the present case also the Respondent provides BPO services which is not with KPO ..... X X X X Extracts X X X X X X X X Extracts X X X X
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