2018 (8) TMI 199

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....e urges only the following reframed questions of law, for our consideration: "(a) Whether on the facts and in the circumstance of the case and in law, the Tribunal was justified in directing to include the entity M/s. Dolphin Medical Services Ltd., as valid comparable even though the functioning comparable of the assessee and the entity M/s. Dolphin Medical Services Ltd., are squarely different? (b) Whether in law and on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the assessee is entitled to get the benefit of section 10B of the Act, on the interest income derived? (c) Whether in law and on the facts of the instant case, was the Tribunal right in holding that an ad....

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....espondentAssessee inasmuch as it is in the business of clinical trial services i.e. functionally broadly similar. We also note that the impugned order of the Tribunal records the fact that this similarity is not disputed by the Revenue before it. We find that the DRP had excluded both Alphageo (India) Ltd., and M/s. Dolphin Medical Ltd. from the list of comparables. This,particularly, in view of the fact that M/s. Alphageo (India) Ltd., is providing seismic survey services to the oil exploration industry. Thus, the Appellant accepted the exclusion of M/s. Alphageo (India) Ltd., from the list of comparables and only appealed against exclusion of M/s. Dolphin Medical Ltd. from the list of comparables. (iv) In the above view, we note ....