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TMI Blog2018 (7) TMI 2101X X X X Extracts X X X X X X X X Extracts X X X X ..... R.Vasudevan, Adv. for Respondent. ORDER Mrs S.Sujatha, This Appeal is filed by the Revenue purportedly raising substantial questions of law arising from the Order of the Income Tax Appellate Tribunal, Bangalore Bench 'C', Bangalore, in IT[TP]A No.1642/Bang/2012 dated 21.11.2014, relating to the Assessment Year 2008-09. 2. The appeal has been admitted on 04.12.2015 to consider the fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... stion of law Nos. 1 and 2: "7. Having regard to the rival contentions and the material on record, we find that the issue covered in favour of the assessee by the order of this Tribunal to which one of us i.e., the Judicial Member is the signatory. We hereby reproduce hereunder the relevant portion of the order for easy reference: "XXXXXXX" Respectfully following the decision of the co-ordin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... been a case of substantial question of interpretation of provisions of Double Taxation Avoidance Treaties (DTAA), interpretation of provisions of the Income Tax Act or Overriding Effect of the Treaties over the Domestic Legislations or the questions like Treaty Shopping, Base Erosion and Profit Shifting (BEPS), Transfer of Shares in Tax Havens (like in the case of Vodafone etc.)' if based on r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Revenue are found to be devoid of merit and the same are liable to be dismissed. 57. We make it clear that the same yardsticks and parameters will have to be applied, even if such appeals are filed by the Assessees, because, there may be cases where the TFbunal giving its own reasons and findings has found certain comparables to be good comparables to arrive at an 'Arm's Length Price& ..... X X X X Extracts X X X X X X X X Extracts X X X X
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