9911796707
TMI Blog2019 (7) TMI 1963X X X X Extracts X X X X X X X X Extracts X X X X ..... engaged in knowledge management systems - Whether ITAT erred in concluding that for the AYs in question, the Assessee had rendered Knowledge Process Outsourcing (KPO) services to its Associated Enterprises which according to the Assessee was contrary to the documents on record? - Revenue on the other hand points out that for these very AYs, on the question of exclusion of comparables, the Revenue ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the ITAT dated 15th December, 2016 in ITA No. 154/Del/2016 for the Assessment Year (AY) 2011-2012 and order dated 11th May, 2017 passed by the ITAT in ITA No. 6648/Del/2016 for AY 2012-2013. 2. While admitting these appeals on 7th February, 2018 the following question of law was framed for consideration. "Did the ITAT commit an error in law in holding that the assessee was engaged in kno ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ITAT have been dismissed by this Court. As such the Appellant‟s grievance on the above finding of the ITAT as far as the present AYs are concerned is academic. 6. In view of the above submission, it is considered appropriate to direct that the impugned order of the ITAT returning the above finding qua the activity of the Assessee for the AYs in question will not constitute a precedent if s ..... X X X X Extracts X X X X X X X X Extracts X X X X
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