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M/S. Dharam Deep Public School,, Delhi vs Dcit Cpc-Tds, Ghaziabad on 5 January, 2018

7. Different risk profile - Company is subject to various risk such as Market Risk, Operational Risk, Financial Risk, IT Risk, Reputational and other Risks etc. Refer Page B478 of Volume 3 of Paper-book In Corning Technologies India (P.) Ltd v. Ts DCIT {[2021] 132 taxmann.com 72 (Delhi -Trib.) - Just Dial held to be a search engine for multifarious activities using ed different platforms, dealing with multiple ag products and not comparable to a captive marketing service provider.
Income Tax Appellate Tribunal - Delhi Cites 53 - Cited by 10 - Full Document

M/S. New Delhi Television Ltd., New ... vs Dcit, New Delhi on 14 July, 2017

P a g e | 26 ITA No.2013/Del/2022 Intercontinental Hotels Group (India) Pvt. Ltd (AY 2018-19) Nokia India (P.) Ltd v. ACIT {[2022] 136 taxmann.com 85 (Delhi - Trib.)} - Just Dial held to be functionally different i.e., operates a local search engine which assists general public in finding information pertaining to nearby area. Further, no segmental data is available and the company owns significant intangible assets in the form of goodwill, application development and unique phone numbers. In view of above material facts especially Just Dial Ltd operating as a local search engine and works as a payment gateway through JD Pay app as difference functions and reasonable to be excluded.
Income Tax Appellate Tribunal - Delhi Cites 278 - Cited by 381 - Full Document

Deputy Commissioner Of Income Tax vs Aimil Limited on 25 January, 2005

In view of the glaring fact that EDCIL (India) Ltd is a Government company earning revenue from Government companies cannot be considered comparable owing to dealings with control entities as per well settled principle of law in case of WSP Consultants India Pvt. Ltd. (ITA 935/17-Del HC) (supra). Therefore, EDCIL (India) Ltd is liable to be excluded
Income Tax Appellate Tribunal - Delhi Cites 8 - Cited by 401 - Full Document
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