Court :
ITAT Bangalore
Brief :
This appeal by the Revenue against the directions of the Dispute Resolution Panel (DRP) dt.29.12.2015 and order passed by the Assessing Officer u/s.143(3) r.w.s. 144C of the Income Tax Act, 1961 ('the Act') for the Assessment Year 2011-12.
Citation :
IT(TP)A No.620/Bang/2016
IN THE INCOME TAX APPELLATE TRIBUNAL
BANGALORE BENCHES “ B ” BENCH: BANGALORE
BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT
AND SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER
IT(TP)A No.620/Bang/2016
(Assessment Year: 2011-12)
Assistant Commissioner of Income Tax,
Circle 3(1)(1), Bangalore. ….Appellant
Vs.
M/s. Inmobi Technologies Pvt Ltd.,
Pebble Beach, Ground Floor, B Block,
Embassy Golf Links Business Park,
Off. Intermediate Road,
Bangalore – 560071 ……Respondent.
PAN AAECM 9170C
Assessee By: Shri L. Bharath, C.A.
Revenue By: Shri G. Guruswamy, CIT (D.R.)
Date of Hearing : 10.12.2020.
Date of Pronouncement : 16.12.2020.
O R D E R
PER SHRI CHANDRA POOJARI, A.M. :
This appeal by the Revenue against the directions of the Dispute Resolution Panel (DRP) dt.29.12.2015 and order passed by the Assessing Officer u/s.143(3) r.w.s. 144C of the Income Tax Act, 1961 ('the Act') for the Assessment Year 2011-12.
2. The revenue has raised various grounds; the crux of the grounds are that the DRP erred in holding that the following comparables to be excluded from the list of comparables that though it satisfies all the qualitative and quantitative criteria adopted by the Transfer Pricing Officer (TPO) in Software Development Segment :
i) Acropetal Technologies Limited
ii) E-Infochips Limited
iii) Infosys Limited
iv) L & T Inoftech limited and
v) R S Softwre
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