2016 (9) TMI 1575

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....by: Shri GR Reddy, CIT Respondent by: Shri T Suryanarayana, Advocate ORDER A Sha Vijayaraghavan,  This appeal by the assessee is directed against the order of Commissioner of Income-tax, Bangalore dated 31.12.2015 and it pertains to the assessment year 2011-12. 2. The Department has filed the following grounds of appeal:  "(1) The directions of the Dispute Resolut....

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....e tax payer in its status of a captive service provider was equivalent to the marketing and technical risk attached to the comparables. The Hon'ble ITAT held that the risk of having a single customer is an anticipated risk which may or may not happen unlike the marketing and technical risks which have to be contemporaneously dealt with by the compa5rbles. The ITAT did not accept that the risk adju....