2018 (2) TMI 2012

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..... dv. ORDER Admit. The Revenue's appeal questioning the order of ITAT concerns itself with the inclusion of three comparables i.e TCS E-serve Ltd., Infosys BPO Ltd. and Excel Infoways Ltd. for the purpose of carrying out the Arms Length Price (ALP determination) mandated by Section 92CA of the Income Tax Act. The assessee is engaged in information technology enabling services and had in its tran .....

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..... . vs. Deputy Commissioner Income Tax, Circle 4(1), ITA 408/2017 and Principal Commissioner of Income Tax, Delhi-2 vs. Baxter India Pvt. Ltd., ITA 499/2017). The Court is of the opinion that no question of law arises on this aspect; the ITAT also returned its finding that functionality of the assessee is similar to Infosys BPO. Likewise with respect to inclusion of R Systems the Court finds no infi .....

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..... s findings with respect to inclusion of M/s. Surya Pharmaceutical Ltd., given the assessee's contention with respect to unavailability of segmented data for the purpose of transfer pricing analysis, in the circumstances of the case? (ii) Did the ITAT fell into error in directing the exclusion of M/s. Excel Infosys, having regard to the judgment of this Court in Chryscapital Investment Advisors ( .....

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