2014 (7) TMI 1249

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....:   Sanjay Kumar, This appeal under Section 260-A of the Income Tax Act, 1961 is sought to be preferred by the Revenue aggrieved by the order dated 27.11.2013 passed by the Income-Tax Appellate Tribunal, Hyderabad Bench "A", Hyderabad, in relation to the assessment year 2007-08 on the following suggested substantial questions of law. 1. Whether, on the facts and in the circumst....

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.... the TPO has been to identify the companies which are engaged in the software development services? 3. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in rejecting companies on the ground of failing the RPT filter being more than 15%, without appreciating the fact that rationale of 25% threshold limit is in accordance with Section 92A(2)(a) of the In....

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....ideration. Insofar as the fourth question of law is concerned, the order under appeal reflects that the Tribunal merely followed the decision of the Karnataka High Court in CIT. v. Tata Elxsi Limited (349 ITR 90) which was also followed by the Tribunal in ITO v. Sak Soft Limited (313 ITR 353) (AT). Though the learned Standing Counsel states that an appeal has been preferred against the decision of....