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TMI Blog2021 (6) TMI 1126X X X X Extracts X X X X X X X X Extracts X X X X ..... e impugned order is set-aside and the matter is restored to the file of the AO/TPO for re-computing the ALP of the international transaction of rendering `Information Technology Support Services in the light of our above discussion. Needless to say, the assessee will be allowed reasonable opportunity of hearing. - ITA No. 1756/PUN/2018 - - - Dated:- 22-6-2021 - Shri R.S. Syal, Vice President And Shri S.S. Viswanethra Ravi, Judicial Member For the Assessee : Shri Darpan Kirpalani, Shri Shaily Agarwal Shri Ajit Tolani. For the Revenue : Shri Navin Gupta. ORDER PER R.S.SYAL, VP : This appeal by the assessee is directed against the final assessment order dated 11-09-2018 passed by the Assessing Offi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee remained partly successful before the Dispute Resolution Panel (DRP) inasmuch as one of the companies chosen by the TPO got excluded. After giving effect to the DRP s order, the AO made the transfer pricing addition of Rs.9.18 crore in the final assessment order, against which the assessee has approached the Tribunal. 3. The only assail by the assessee is to the inclusion of MPS Limited in the final set of comparables. This company was chosen by the TPO as comparable. The assessee raised objection against its functional similarity, which was jettisoned by the TPO. The DRP also did not provide any succor to the assessee in this regard. 4. We have heard both the sides through Virtual Court and gone through the relevant material ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ers have started to ask for. As such, MPS Limited has a first-mover advantage in exploiting the market and establishing itself as the premier technology solutions provider for publishers . . . . . . . . Similar other solutions are being developed at MPS Limited as R D based on the market requirements. A copy of its Profit and loss account is available at page 135 of the paper book, which shows Revenue from Operations at Rs.18,829.21 lakh. Note no. 2.7 of its Financial Statements with the caption `Revenue recognition reads : Revenue is recognized on delivery of projects or as per terms specified in contracts/purchase orders received from customers. Revenues for web-site design and development are recognized based on the percentage of com ..... X X X X Extracts X X X X X X X X Extracts X X X X
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