2021 (1) TMI 1363

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.... the following prayers: a) "Formulate the substantial question of law stated above; b) Allow the appeal and set-aside the impugned order of the Income Tax Appellate Tribunal, Bengaluru 'C' Bench bearing in IT(TP) A No.755/B/2017 dated 07.07.2017; and c) Pass such other suitable orders including order as to costs as this Honorable Court may deem fit to grant in the facts and circumstances of the case in the interest of justice and equity." Whereas ITA No.321/2018 is filed u/s.260-A of the Income Tax Act with the following prayer: "WHEREFORE, it is respectfully prayed that this Hon'ble court may be pleased to:- a) Formulate the substantial question of law stated above; b) Al....

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....IV. Whether, on the facts and circumstances of the case, the Tribunal is right in law in refusing to recall its order to consider the ground on the Assessing Officer/Transfer Pricing Officer failing to follow directions of the Dispute Resolution Panel to compute margin before depreciation and provisions for bad and doubtful debts? V. Whether, on the facts and circumstances of the case, the Tribunal is right in law in refusing to recall its order to consider the ground on treating Technical services and software testing services as a separate & independent function when the same is closely linked with the manufacturing activity? VI. Whether, on the facts and circumstances of the case, the Tribunal is right in law in refusin....