2019 (4) TMI 1391

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ge the judgment of the Income Tax Appellate Tribunal, Mumbai ("the Tribunal" for short). 2. Following questions are presented for our consideration:- "(a) Whether on the facts and in the circumstances of the case, the Tribunal is correct in law in directing the Assessing Officer to include ICRA Management Consultancy Services Ltd., Kinetic Trust Limited in the set of comparable companies while....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ite the opposition by the Department. Learned counsel for the Revenue brought to our notice an order dated 17.11.2016 passed in the Revenue's Income Tax Appeal No. 1051 of 2014 in which such an issue had been raised but not entertained by the Court. In that view of the matter, Question No. (a) is not entertained. 4. Question No. (b) pertains to a markup of 3% adopted by the TPO on the comparativ....