2024 (12) TMI 852

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... parables rejected or introduced seem to be making marginal impact in the margins. At the same time the assessee is a debt free company, therefore, the two disallowances on account of provision of software services and interest outstanding receivables appear to be quite arguable. As a consequence of above, the present stay application is allowed and demand for A.Y.2020-21 is stayed for a period of .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... d by the assessee. However, modified the comparable by rejecting two comparables and adding three and accordingly disallowance of Rs. 47,191,801/- was made on account of provisions of software and other services and TPO also considered the outstanding receivables beyond 30 days marked period as unsecured loans advance to AE s and made disallowance of Rs. 3194139/- on account of interest outstandin .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... 016) wherein this company has been considered as comparable to software development services company. It was submitted by Ld. AR that at the same time three comparables have been added which are not actually according to the profile activities of this company. 4. The Ld. AR submitted that if any one of the fresh comparables introduced by the TPO is rejected or if any one of the assessee s comparab .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X