(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 09.11.2016 passed in IT(TP)A No.441/Bang/2011 (The Income Tax Officer v. M/s.Acusis Software India Pvt. Ltd.) for A.Y.2004-05.
(2.) The proposed substantial questions of law framed in the Memorandum of appeal by the Appellants-Revenue are quoted below for ready reference:-
(3.) Regarding 1st substantial question of law:-