erred in
deleting the relevant transaction of M/s ICRA Techno Analytics Ltd. As one of
the comparable without appreciating the fact that ... ICRA Techno Analytics
Ltd. is also in the business of ITes Services.
3. The appellant prays that the order of CIT(A) on the grounds
correct in rejecting
the comparable taken by the assessee i.e. ICRA Techno Analytics Ltd despite
TPO having established the functional similarity ... namely Acropetal Technologies Ltd., Eclerx Services
Pvt. Ltd., Accentia Technology Ltd. and ICRA Techno Analytics Ltd.
The TPO arrived at the following set of comparable
different as submitted by assessee reproduced as
under:
Credit Rating given by ICRA
Credit Rating given to Torrent Pharmaceuticals Ltd by ICRA
during ... 2009-10.
ICRA has reaffirmed LAA rating to Long Term fund based limits of
Rs.4700 million indicating high credit quality. Further the ICRA
credit rating of RPL
The credit rating of RPL granted by ICRA Limited is downgraded below
BBB.
11.23 Pledged Securities
(g) If there ... default and comply with contractual
terms. Counsel also submitted that upon ICRA downgrading the shares of
RPL from BBB to BB negative plaintiffs should have
erred in directing the TPO/AO to exclude the
comparable M/s ICRA Online Ltd & M/s Sundaram Business
Services Ltd. by applying ... Bench members to accept Sundaram as a comparable company.
Ground No.16: ICRA Online Limited ("ICRA Online") ought to be
rejected from
Appellant inrelation to
selection/rejection of comparable companies;
2.4. Rejecting ICRA Management Consulting Services Limited, IDC India
Limited and Mecklai Financial Services Limited as comparable ... assessee for benchmarking its
international transactions had selected three comparables viz. (i) ICRA
Management Consulting Services Ltd; (ii) IDC (India) Ltd; and (iii)
Mecklai Financial
been
held:
"13. As regards Accentia Technologies Ltd. and ICRA Online Ltd. this
Tribunal in the assessee's own case for the Assessment ... been
held:
"13. As regards Accentia Technologies Ltd. and ICRA Online Ltd. this
Tribunal in the assessee's own case for the Assessment
companies as comparables:
Acropetal Technologies Ltd
E Zest Solutions
E-infochips Ltd
ICRA Techno Analytics Ltd
Persistent Systems & Solutions
11. The Ld. DRP while ... Technologies Ltd.,
(ii) e-Zest Solutions Ltd.,
(iii) E-infochips Ltd.,
(iv) ICRA Techno Analysts Ltd.,
(v) Persistent Systems and Solutions
profit margin for FYs 2000-01 and 2001-02, included CRISIL
Limited, ICRA Limited and Vimta Labs Ltd. in the final set of
comparables ... CRISIL Ltd. 48.49%
2 Gilcon Project Services Ltd. -2.90%
3 ICRA Ltd. 39.67%
4 EIL 17.16%
5 KITCO Ltd. -.89%
6 NIS Sparta
have
erred by selecting functionally dissimilar companies (including
CRISIL Limited and ICRA Limited) to the final set of
comparables for the impugned transaction and have ... CRISIL Ltd. 54.42%
2 Gilcon Project Services Ltd. -.97%
3 ICRA Ltd. 52.47%
4 IGE (India) Ltd. 5.86%
5 KITCO Ltd. .68%
6 NIS Sparta