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2019 (5) TMI 1690 - ITAT PUNETP Adjustment - comparable selection - inappropriate selection of comparables which are functionally different from that of the assessee - HELD THAT:- Asessee is engaged in the “business of designing and development of chip, integrated circuits and storage components and allied services” for its holding company AMCC, USA thus companies functionally dissimilar with that of assessee need to be deselected from final list. Two comparables i.e. (i) Eclerx Services Limited and (ii) Genesys International Corporation Limited are required to be excluded for the purpose of benchmarking of the international transactions. Rejection of the risk adjustment - We set-aside the orders of the DRP/TPO on this issue and direct the Assessing Officer to allow the risk adjustments. The Assessing Officer shall grant reasonable opportunity of being heard to the assessee in accordance with the set principles of natural justice.
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