In the result, the revenue’s appeal is dismissed and assessee’s appeal is partly allowed
Bench: Smt. P. Madhavi Devi & Shri Jason P.Boaz
property rights (IPRs). It was also submitted by the learned Authorised Representative that :- (i) the co-ordinate bench of this Tribunal in the case of 24/7 Customer.Com Pvt. Ltd. in ITA No.227/Bang/2010 has held that a company owning intangibles cannot be compared to a low risk captive service provider who does not own any intangible and hence does not have