PR. COMMISSIONER AND OTHERS Vs. M/S SUNQUEST

JUDGEMENT

(1.) Mr. E.I. Sanmathi, Adv. for Appellants - Revenue Mr. Sandeep Huilgol, Adv. for Respondent - Assessee 1. The Appellants-Revenue have filed this appeal under section 260A of the Income Tax Act, 1961, raising purportedly certain substantial questions of law arising from the order of the ITAT, 'A' Bench, Bangalore, dated 11.06.2015 passed in IT(TP)A No.1302/Bang/2011 (The Income Tax Officer v. M/s.Sunquest Information Systems (India) Pvt. Ltd.,) for A.Y.2005-06.

(2.) The proposed substantial questions of law framed in the Memorandum of appeal by the Appellants-Revenue are quoted below for ready reference:-

(3.) The learned Tribunal, after discussing the rival contentions of both the Appellants-Revenue and the Respondent-assessee, has given the following findings against Revenue with regard to various issues raised before it with regard to 'Transfer Pricing' and 'Transfer Pricing Adjustments' made by the concerned authorities below. We consider it appropriate to quote from the order of Tribunal rejecting the Application seeking a review before Tribunal as hereunder:-