2016 , observed
that exclusion of three comparables by the ITAT, where the
acquisitions resulted in higher profits, was not unreasonable. Since
the Accentia Technologies ... mentioned. Our attention was also drawn to the decision of the Hyderabad
ITAT Bench in the case of Capital IQ Information Systems India
considered as a comparable company by the Hon'ble ITAT
in the case of another software development services company such as the assessee ... 2010-11. Our attention was
drawn to the decision of ITAT, Kolkata in the case of Labvantage Solution
HDFC Bank Ltd. [Bombay High Court].
b. Kolte Patil Developers Ltd. [ITAT Pune, copy enclosed in the
paper book]
In view of the above decisions ... 1469 and 1470/Kol/2019 decided on 5th December, 2019 by the
ITAT, Calcutta;
(ii) DCIT v. Graphite India
squarely covered by
the separate decisions of the various Benches of the ITAT including the jurisdictional
ITAT, Jodhpur Bench, Jodhpur. Following orders were furnished ... assessee, which are placed on record:-
a] The Hon'ble ITAT Jodhpur Bench in case of Mohangarh
Engineers and Construction Company
approved in various Co-ordinate
Bench decisions. The Co-ordinate Bench of ITAT in the case of
Adaptec (India) P. Ltd., Vs. ACIT ... ACIT vs.
M/s. Toshiba India P. Ltd., 2010-TII-14-ITAT-DEL-T.P.
6.2.2. The learned departmental representative however supported the
orders
Ashok Kumar Bansal - ITA No. 289/Agra/2009 (Agra ITAT)
(iv) ACIT vs. Amita Agarwal & Others - ITA Nos. 247/(Kol)/ of 2011 (Kol ITAT ... Others vs. DCIT - IT(SS))A Nos. 22-26/Kol/2p11 (Kol ITAT)
(vi) Surya Prakash Toshniwal vs. ITO - ITA No. 1213/Kol/2016
assessee company has not changed
over the years as captured by ITAT in its order ... does not undertake any AMP expenditure.
5.01.1 It is seen that the ITAT Delhi Bench in Agnity India Technologies P.
Ltd. vs. ITO Ward
amalgamation during the FY 2006-07 and relied upon decision
rendered by ITAT, Delhi Bench in COWI India P. Ltd. (ITA
No.5709/Del/2011 ... available at pages 699 to 715 of the Paper
Book-III) and ITAT, Hyderabad Bench in case of Capital IQ
8 ITA No6455
cannot be sustained. Our attention was also drawn to the decision of ITAT in
the case of Suvaprasanna Bhattacharya vs ACIT in ITA No.1303 ... before us.
8. The learned DR relied on three decisions of Mumbai ITAT viz., (i) Dhanraj Mills Pvt. Ltd.
Vs. ACIT ITA No.3830
cannot be sustained. Our attention was also drawn to the decision
of ITAT in the case of Suvaprasanna Bhattacharya vs ACIT in ITA
No.1303 ... learned DR relied on three decisions of Mumbai ITAT viz., (i) Dhanraj Mills
Pvt. Ltd. Vs. ACIT ITA No.3830 & 3833/Mum/2009 dated
