2014 (7) TMI 1238

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....Jyoti Sengupta This appeal is sought to be preferred and admitted against the judgment and order of the learned Tribunal dated 29.11.2003 passed in I.T.A.No.1445/Hyderabad/2010 in relation to the assessment year 2006-07 on the following suggested questions of law. 1. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in rejecting comparable companies on the ....

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....anies merely on the grounds of extraordinary events like merger/demerger change in controlling stake, when the tax payer did not demonstrate effect of such events on the profitability of the comparable? 5. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in accepting the contentions of the tax payer and rejecting the comparables without appreciating the fact....

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....for the Revenue, and gone through the impugned judgment and order of the learned Tribunal. In paragraph 11 of the impugned judgment and order, on the question of exclusion of communication expenses, the learned Tribunal has relied on the Special Bench Judgment of the Tribunal in the case of Saksoft and also the decisions of other Coordinate Benches in the case of Prithvi Information Solutions Ltd....