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TMI Blog2019 (4) TMI 1390X X X X Extracts X X X X X X X X Extracts X X X X ..... they are not functionally similar. Notably, the Tribunal s earlier decision in case of Berh India Ltd, on which reliance was placed in the present judgment does not seem to have been carried in the appeal by the Revenue. On such ground, Income Tax Appeal is dismissed. - INCOME TAX APPEAL NO. 308 OF 2017 - - - Dated:- 16-4-2019 - AKIL KURESHI And SARANG V. KOTWAL, JJ. Mr. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the nature of elaborating the first question which we have reproduced above. The issue pertains to transfer pricing adjustment in case of the respondent assessee. The Revenue wanted to include in the transfer pricing study, the cases of Rolta India Ltd and KLG Systels Ltd. The assessee objected to the same on the ground that functionality of the two companies was different since they were engag ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vices arose before the Tribunal in the case of Behr India Ltd. Vs. Addl. CIT, wherein the Tribunal in ITA No. 1376/PN/2010, relating to assessment year 2006-07 and also in ITA No. 568/PN/2013, relating to assessment year 2008-09, vide order dated 30.09.2014 held that both Rolta India Ltd. and KLG Systel Ltd. were functionally dissimilar and same had to be excluded from the final set of comparables ..... X X X X Extracts X X X X X X X X Extracts X X X X
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