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iki saniye sure veriyorum, hani bazen koltuk kontrolsuzce yatiyor, belki donup geri alirlar diye. Commissioner of Income Tax. Vikram Singh TS-148-HC-2017 (DEL) (WP(C) 6825/2016) Disclaimer: The contents of this document are solely for informational purpose. Further, on similar facts, the Apex Court in Union of India. On appeal, after referring to the provisions of Rule 10C and considering the fact that the TPO had not considered third party comparable cases, and that the details of the actual services rendered by the assessee were not known, the Tribunal remitted the matter. Elitecore Technologies Private Limited TS-129-itat-2017(Ahd) ITA.508/Ahd/2016. The Tribunal remitted the issue of addition on account of AMP for AYs and held that the contentions of the assessee viz.

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As it was engaged in providing outsourced software product development services and technology solutions to independent software vendors, it constantly invested in new IP solutions, derived significant revenue from export of software services and products and did not declare segmental results based on its services. However, TPO rejected CUP method used by assessee on the basis that assessee had not given any evidence to support the applicability of CUP method and adopted tnmm as MAM, which was upheld by the DRP. The Tribunal relying on the decision in the case of Control Techniques India Pvt. Curam Software International. E-Zest Solutions Ltd as it rendered product development services and high end technical services under KPO category. The Apex Court held that where assessee-company had sold its entire running business with all assets and liabilities in one go, it was a slump sale of a long term capital asset and should be taxed accordingly. The Tribunal held that the assessee engaged in providing contract software development services to its AEs could not be compared to: Celestial Labs Ltd as the company was engaged in clinical research and manufacture of bio products. Ecis bucus duracaksin oyle, agzinda onundekinin cantasi, kicinda arkandakinin gitari. 2695 of 2016) Section 40A(2) 108.

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