2021 (4) TMI 255

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.... 6.11.2017. 2. The brief facts of the case shows that assessee company is a subsidiary of Verint Systems Inc., USA and is primarily engaged in providing pre-sales and post-sales support services to its Associated Enterprises (AEs) situated at Israel, US and UK. It provides the services of marketing assistance and territory support to the sales team of the associated enterprises by way of business consultancies, solutions specialists and pre-sales engineers who during the sales process, determine the customer requirement and develop technical response to those requirements. Post-sales support services comprises of implementation assistance, training, consulting and maintenance of sales to the customers of US and UK AEs. 3. Assessee fil....

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....- by order passed under Section 92CA(3) of the Income Tax Act on 29.01.2014. 6. The above adjustment was incorporated by the ld. Assessing Officer and passed an order under Section 143(3) of the Act on 15.05.2014 determining total taxable income of the assessee at Rs. 5,21,26,664/- against the returned income of Rs. 1,58,35,913/-. Assessee aggrieved by that order preferred an appeal before the ld. CIT (Appeals). 7. The ld. CIT (Appeals) directed for exclusion of certain comparables against which the Revenue is aggrieved and has challenged the exclusion of TSR Darashaw Ltd. directed by the ld. CIT (Appeals). Thus, in I.T. Appeal 3961 (Del) of 2018 the ld. Assessing Officer is aggrieved with this order to that extent of the CIT (Appeals....