J U D G M E N T

MANMOHAN, J (Oral):

C.M.Nos.19916-19917/2022 Keeping in view the averments in the applications, delay in filing (75 days) and re-filing (144 days) the present appeal is condoned. Appeal is taken on record.

Accordingly, the applications stand disposed of.

ITA No.126/2022

1. Present Income Tax Appeal has been filed challenging the order dated 26th February, 2019 passed by Income Tax Appellate Tribunal (‘ITAT’) in ITA No. 1883/Del./2015 for the Assessment Year 2010-11.

2. Learned counsel for the Appellant states that the ITAT has erred in rejecting Persistent Systems Ltd., E-Infochips Banlagore Ltd., Infinite Data Systems Pvt. Ltd. and Zylog Systems Ltd. as comparables.

3. Learned counsel for the appellant further states that the grievance of the Appellant/Revenue is that the ITAT has excluded the aforesaid four comparables for benchmarking the international transaction without giving clear and cogent reasons.

4. A perusal of the impugned order reveals that the ITAT has given the cogent reasons for rejecting the aforesaid four companies as comparables.

The relevant portion of the impugned order is reproduced hereinbelow:-

“PERSISTENT SYSTEMS LTD. (PERSISTENT)

16. Persistent is ta