assessee also filed an additional ground under Rule 11 of
the ITAT Rules, which read as under :
a) "that the learned ... this
company as comparable are found to be acceptable. The decision of
ITAT (Mumbai) in the case of Telcordia Technologies Pvt. Ltd. v. ACIT
(supra
rejected as
comparable. The relevant observations of DRP as extracted by the
ITAT in its order are as follows:
"In regard to Accel Transmatics ... this
company as comparable are found to be acceptable. The decision of
ITAT (Mumbai) in the case of Telcordia Technologies Pvt. Ltd. v.
ACIT (supra
operating in nature in AY 2009-10 by the Honourable ITAT.
6.4 Honourable DRP have erred in law and on facts by ignoring the information ... relevant asst. year; in tune with the decision of the ITAT, Mumbai Bench in
the case of Technimont ICB House V DCIT
assessee's own case for asst.
year 2005-06, Bangalore ITAT, in the decision reported in (2015)
61 taxman.com 81 (Bangalore Trib.), took ... that in some of the
decisions rendered by the Bangalore Bench of ITAT threshold limit
of 25% of sales was applied to exclude companies
Shri Sharath Rao, CA
Respondent by : Ms. Neera Malhotra, CIT(DR), ITAT, Bengaluru
Date of hearing : 03.10.2017
Date of Pronouncement ... Assessee relied on the decision of the Bangalore Bench of ITAT in
Assessee's own case
ought to have considered the fact that the
various decisions of the ITAT, Bangalore Bench relied upon by her, have not
been accepted ... Corporation of India (1988)
174 ITR 682 and the decision of the ITAT, Chennai Bench in the case of
Neyveli Lignite Corporation Ltd. Vs. ACIT
Prasad & Umashankar Gautam, Advocates.
Revenue By : Ms. Neera Malhotra, CIT (DR) (ITAT)-2, Bengaluru.
Date of Hearing : 05.09.2017.
Date of Pronouncement ... 1119/Bang/2011 and by the ITAT, Delhi Bench in the case
of Transwitch India Pvt. Ltd. in ITA No.6083/Del/2010
relied on the decision of
the Mumbai Bench of the ITAT in the case of Bexis Kier Dabhol, SA
vs. DCIT (I Tax), Circle ... learned AR also placed
reliance on this decision of Mumbai ITAT and another decision of
AAR in the case of M/s GE Strategic Investment
case of Bank of Bahrain & Kuwait
[2010-TIOL-447-ITAT MUM-SB], the Apex Court decision in the case
of Woodward Governor India ... assessee also placed reliance on the following judicial
decisions:-
(a) ITAT, Delhi Bench decision in the case of Agnity India
Technologies India
Shri. Tata Krishna, Advocate
Respondent by : Shri. Pradeep Kumar, CIT(DR)(ITAT), Bengaluru
Date of hearing : 14.10.2021
Date of Pronouncement : 25.10.2021
ORDER ... decisions rendered on the above
issue by the various decisions of the ITAT Bangalore Benches in favour of
the Assessee and in favour
