The Pr. Commissioner Of Income Tax -3 v. Fluor Daniel India Pvt. Ltd. Through None

$~37 * IN THE HIGH COURT OF DELHI AT NEW DELHI+ ITA 665/2019 THE PR. COMMISSIONER OF INCOME TAX -3 ..... Appellant Through Mr. Ruchir Bhatia, Sr. Standing counsel versus FLUOR DANIEL INDIA PVT. LTD. Through None ..... Respondent CORAM: JUSTICE S.MURALIDHAR JUSTICE TALWANT SINGH % O R D E R19.07.2019 1. This is an appeal by the Revenue against an order dated 17[th] January, 2019 passed by the ITAT in ITA No. 973/Del/2016 for the Assessment Year 2011-2012. 2. The issue sought to be urged by the Revenue concerns the exclusion of four comparables by the ITAT and inclusion of one as suggested by the Assessee. 3. The Court notes that the ITAT has given detailed reasons in support of its conclusions by discussing each of the comparables from the point of view of the functionality assets and risk test in terms of Rule 10B of the Income Tax Rules. 4. The Court is unable to find any legal infirmity in the impugned order which gives rise to any the substantial question of law that requires determination. 5. The appeal is accordingly dismissed. S.MURALIDHAR, J. JULY 19, 2019 mw TALWANT SINGH, J.