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TMI Blog2019 (7) TMI 1147X X X X Extracts X X X X X X X X Extracts X X X X ..... ITAT has given detailed reasons why the comparables should be rejected either because of failing the filter or because of functional dissimilarity. In some instances, the earlier decisions concerning this very Assessee have been followed. The Court is not persuaded that on the issue of exclusion and inclusion of comparables, particularly when the decisions of this Court on the topic including ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ribunal (ITAT) in ITA No.6779/Del/2015 for the Assessment Year 2011-2012. 3. The issue sought to be urged by the Revenue concerns the ITAT accepting the plea of the Assessee regarding exclusion and inclusion of comparables for the purposes of determining the Arm s Length Price ( ALP ) of the international transactions involving the Assessee. 4. The Assessee was set up as a wholly ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5. The Transfer Pricing Officer (TPO) rejected 7 of the 11 comparables selected by the Assessee either on account of failing of filters or functional dissimilarities. The comparables were specific to each of the segments i.e. EDS, FAS and IT Infra. A fresh search was undertaken by the TPO and a draft assessment order prepared which was challenged by the Assessee before Dispute Resolution Panel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7. Learned counsel for the Revenue has placed before the Court a detailed chart which indicates for each comparable the findings of the TPO and the DRP and the ITAT. This has been done segment wise. Likewise learned counsel for the Assessee, who appears on advance notice, has also prepared three similar charts for each of the segments for perusal by this Court. 8. Having perused t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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