2023 (1) TMI 1089

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....dhur Agrawal i/b Mr. Upendra Lokegaonkar i/b Mint & Confreres. P.C. This is an appeal under Section 260A of the Income Tax Act, 1961 ("the Act") against the Order of the Tribunal dated 11 January 2017 in Income Tax Appeals ITA(TP) NO.927/Mum/20167 and ITA(TP) NO.902/Mum/2016 for the assessment year 2011-12. 2. We have heard learned Counsel for the parties. 3. The Appeal is admitted on ....

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.... VAK software and Exports Ltd (CVSEL) as a comparable for ITeS, even though segmental results show that the Company had persistent loss in the comparable segment and comparable segment failed the turnover filter of Rs.1 Crore? 3. Whether, on the facts and in the circumstances of the case and in law, the ITAT is justified in directing the AO to include M/s R Systems Ltd (RSL) as a comparab....

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....es ? B. Whether, on the facts and in the circumstances of the case and in law, the ITAT is justified in directing the AO to include M/s ICRA Management Consulting Services Ltd (ICRA), engaged in rendering Managing Consultancy Services, as comparable for benchmarking of ALP of investment advisory services ? C. Whether, on the facts and in the circumstances of the case and in law, ....

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....ed services. DRP held that Motilal Oswal Advisors India Pvt. Ltd (MOIALP) be taken out from the list of valid comparables. In regard to ICRA Management Consultancy Services (ICRA) and IDC India Limited (IDCL), DRP held that the functions performed by ICRA were different from the functions carried out by the Petitioner and ICRA was providing consultancy services and was engaged in management consul....