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TMI Blog2019 (5) TMI 1063X X X X Extracts X X X X X X X X Extracts X X X X ..... tself earlier in the list of comparables submitted by it, later it was noticed that GICL was engaged in diversified operations providing high-end and complex services such as GIS Consulting, 3D Mapping, Navigation Maps, Remote sensoring, etc. On the other hand the Assessee was engaged only in providing back office IT enabled services. GICL operated as a full-fledged risk taking entrepreneur wherea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dent Through: Mr. Vishal Kalra and Mr. S.S. Tomar, Advocates O R D E R CM APPL. 22485/2019 (Delay of 145 days in refiling appeal) 1. For the reasons stated in the application, the delay in re-filing the appeal is condoned. The application is disposed of. ITA 487/2019 2. This appeal by the Revenue is directed against an order dated 18th June, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) noticed international transactions having been entered into by the Assessee in relation to the IT enabled services, and that the Assessee had selected TNMM for computation of Arm s Length Price (ALP), the matter was referred to the Transfer Pricing Officer (TPO). By the order dated 14th December, 2012 the TPO did not agree with the various filters used by the Assessee for the transfer pricing st ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o delete the transfer pricing adjustment. The DRP accepted the submission of the Assessee that GICL should be omitted from the list of comparables. A final assessment order was then passed under Section 143(3) of the Act by the AO deleting the earlier proposed transfer pricing adjustment. 8. The Revenue being aggrieved by the said order of the AO, filed an appeal before the ITAT. By the i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d not own any significant intangibles. It depended entirely on the intellectual property rights owned by the holding company. 9. The reasons given by the DRP, concurred with ITAT, for excluding GICL as a comparable appears to be justified. No substantial question of law arises that calls for interference by this Court. 10. Accordingly, the appeal is dismissed. - - TaxTMI - ..... X X X X Extracts X X X X X X X X Extracts X X X X
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