2017 (9) TMI 2013

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..... sis of the functional profile of the tested company vis-a-vis that of the comparable and has given cogent reasons for excluding the said comparable. The Court is not persuaded to hold that this factual finding is perverse. It accordingly declines to frame a question on this issue. Nature of expenses - Expenditure incurred on software licenses - capital or revenue expenditure - HELD THATR:- Th .....

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..... ITA 816/2017 2. This is an appeal under Section 260A of the Income Tax Act, 1961 ( the Act ) by the Revenue against the order dated 25th August, 2016 passed by the Income Tax Appellate Tribunal ( ITAT ) in ITA No.7584/Mum/2012 for the Assessment Year ( AY ) 2008-09. 3. Two issues have been urged by the Revenue for consideration. The first concerns the omission by the ITAT of Celestial .....

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