2017 (11) TMI 464

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....the Respondent: Mr. Kamal Sawhney and 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 comp....

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....rables and derived the ALP bringing to tax a sum of 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....

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.... revenue derived by this entity was from consultancy services. 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 ....