2024 (12) TMI 852

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....rwal CA Ms. Suchita, Kanodia, AR For the Respondent: Sh. Om Prakash, Sr. DR ORDER PER ANUBHAV SHARMA, JM: The stay application in hand has been filed by the applicant / assessee for stay of demand of tax for A.Y.2020-21. 2. The Ld. AR has pointed out that the assessee is a captive services provider to associate enterprises and provided transfer pricing report in transfer pricing stu....

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....to submit that on the basis of difference in financial year comparable cannot be rejected. As with regard to the other comparable Infomile Technologies Limited, it is submitted that it is also engaged in providing software services developing etc. similar to applicant business and was a functionally comparable company. Reliance is placed on the Tribunal's order in the case of M/s. Aithent Technolo....