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2022 (7) TMI 1391 - ITAT BANGALORETP Adjustment - comparable selection - Turnover and Abnormal Profits Filter - exclusion of Celestial Biolabs Ltd. raised - HELD THAT:- We are of the opinion that, this comparable cannot be compared with that of the assessee which is a captive service provider, as observed by this Tribunal vide order dated 06/04/2018. Also recorded by this Tribunal that, the assessee before us is engaged in the business of providing software development and other related support services to the SAP AG Group companies and conducts its operations from various undertakings registered under STPI scheme. Based on the above analysis, we hold that this comparable is not a fit company to be included in the list of comparables to compute the ALP of the transaction. Exclusion of comparables as functionally dissimilar with that of assessee as captive service provider.
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