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2016 (8) TMI 1471 - ITAT DELHITP Adjustment - Comparable selection - HELD THAT:- Comparable functionally dissimilar with that of assessee a company incorporated in Korea and has project offices (PO) in India for carrying out on-site work in relation to specified licensing, coordination and other activities. During the year under consideration, assessee had 3 project offices in India being Rotem RS 1, Rotem RS 3 and BRCL. The role of the Rotem RS1 project office, is to overview the replacement/modification job being undertaken by outsourcing companies and lace with the MRC personnel in relation to maritime and troubleshooting in relation to rolling stock supplied under contract Rotem RS 3 undertakes the supply of components to BEML and is not involved in on-site activities need to be deselected from selected from final list.
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