AI Drafter - (New and Powerful) 
Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter. 
TaxTMI 
TaxTMI 
2016 (10) TMI 1035
X X X X Extracts X X X X
X X X X Extracts X X X X
....e along with Mr. Gautam Swarup, Advocate. ORDER The revenue in this appeal urges two substantial questions of law. The first pertains to exclusion of two comparables i.e. M/s Infosys Ltd. and M/s. Persistent Systems Ltd. The second question urged is the treatment of foreign exchange gain or loss in the transfer price determination of ALP. It is urged that foreign exchange gain or loss, as th....
X X X X Extracts X X X X
X X X X Extracts X X X X
....h respect to M/s Persistent Technologies, it is pointed out that in a previous order in ITA No. 279/2016 dated 04.05.2016 (Principle Commissioner of Income Tax vs. M/s Cashedge India Pvt. Ltd) held that having regard to the rules i.e. Rule 10 B to 10 E of Income Tax Rules, the data of M/s Persistent Systems Ltd- could not have been included. Here, it is urged that the assessee is also a member of ....