2021 (12) TMI 1474

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

..... For the Respondent : Shri Rajendra Kumar, CIT, (D.R.) ORDER PER SHRI S.S. GODARA, J.M.: This Revenue's appeal ITA 423/Hyd/2020 and assessee's C.O. No.25/Hyd/2020 arise against the ACIT, Circle 16(2), Hyderabad assessment dt.28.01.2016 framed in furtherance to Dispute Resolution Panel-1 (DRP), Bangalore's directions in F.No.175/DRP-BNG/2015-16 involving proceedings under Section 144C(5) o....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... Scientific Technologies Ltd. (vii) Mastiff Tech P. Ltd. and (viii) TCS E-serve Ltd.; respectively, from the array of comaprables. 4. The assessee has drawn a strong support form the DRP directions extracted above DRP's remand directions to the A.O./TPO for exclusion of the foregoing eight comparables. It has also filed voluminous paper book regarding each and every comparable entity as well as v....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....rmed Technologies Ltd. fails revenue filter of 75% applied by the TPO himself. M/s. Jeevan Scientific Technologies Ltd. has also been rejected on the very turnover filter as well as in light of huge fluctuating margin pinpointing abnormal trend. Same factual position prevails regarding M/s. Mastiff Tech P. Ltd. having bad debts influencing its profit margin thereby reducing them from 21.78% to 2.2....