ACIT vs Software Paradigms Infotech Pvt. Ltd.
Whether the Revenue's appeal is maintainable given the CBDT Circular No.17/2019 monetary limit --- Held No, dismissed in limine. Whether the assessee's request for exclusion of four comparables (two in Software Development Segment and two in ITES Segment) from transfer pricing analysis should be allowed --- Held Yes, following precedent tribunal orders.
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