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TMI Blog2024 (2) TMI 1486X X X X Extracts X X X X X X X X Extracts X X X X ..... [Transactional Net Margin Method] as an appropriate method is deployed to iron out the differences among the comparables for the sake of a broad comparison - HELD THAT:- We find that the issue of TCS e-Serve being used as a comparable, came up for consideration in PCIT v. B.C. Management Services Pvt. Ltd[ 2017 (12) TMI 255 - DELHI HIGH COURT] wherein held Income-tax Appellate Tribunal observed t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lra and Mr. S. S. Tomar, Advs. ORDER 1. The Commissioner impugns the judgment rendered by the Income Tax Appellate Tribunal ["ITAT"] dated 02 April 2019 and has suggested the following questions for our consideration: "A. Is ITAT justified in deleting the comparable TCS e-Serve on the basis of the said comparable having a high profitability and brand when TNMM [Transactional Net Margin Method ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d high value financial services relating to consultancy business and solution testing besides the web content management merchandising execution, web analytics, etc. This functional dissimilarity and absence of segmental data led to its exclusion as a comparable. Those are findings of facts based upon record. Consequently, exclusion of E-clerx was in order and cannot be interfered with. 13. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ut for exclusion. The Income-tax Appellate Tribunal recorded that the brand value associated with TCS Consultancy reflected/impacted TCS E- serve profitability in a very positive manner. This inference too in the opinion of the court, cannot be termed as unreasonable. The rationale for exclusion is therefore upheld. The assessee was aggrieved by the inclusion of Accentia, a software development co ..... X X X X Extracts X X X X X X X X Extracts X X X X
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