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In the result, appeal is partly allowed
Bench: Shri Saktijit Deyand Shri N.K. Pradhan
75% IT revenue filter applied by the Transfer Pricing Officer. The contention of the learned Departmental Representative that education service is not acceptable as education service cannot be compared to IT service. Moreover, as rightly brought to our notice by the learned Sr. Counsel for the assessee, the company is also engaged in e– learning and digital content service which