2017 (11) TMI 464

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....Mr. Shikhar Garg and Mr. Prashant Maherchandani, Advs S. RAVINDRA BHAT, J. (OPEN COURT) CM No. 39550/2017 (condonation of delay) For the reasons stated in the application, the delay in filing the appeal is condoned. Application is disposed of. ITA 935/2017 1. The Revenue's appeal urges that the impugned order to the extent it excluded three comparables in ALP determination, of the assessee....

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.... Rs. 6,55,34,938/-. The DRP to which the assessee appealed, deleted 7 comparables and at the same time included 7 more. After giving effect to the DRP's direction, final adjustments of RS. 3,87,54,545/- was made by the AO. 5. Being aggrieved the assessee filed an appeal challenging inclusion of 3 comparables i.e. Ashok Leyland Projects Services Ltd., Kitco Ltd. and Mitcon Consultancy & Engineerin....

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....ices. Besides it is also engaged in diversified activities such as training and engaging in laboratories and research etc. 8. We have heard the counsel for the Revenue who urges that the rationale for exclusion of three comparables which were high income entities is unpersuasive. 9. This Court is of the opinion that the rationale that Ashok Leyland was deriving major part of its revenue from win....