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2020 (2) TMI 1279 - AT - Income TaxTP Adjustment - Arm’s Length Price (ALP) test as provided u/s.92 - upward revision and adjustment made to the price at which international transaction was carried out by the Assessee with its AE in respect of Software development Services(SWD services) - HELD THAT:- Companies functionally dissimilar with that of assessee need to be deselected engaged in providing software development services (SWD services) to its Associated Enterprises (AE) from final list. Companies having turnover more than 200 crores upto 500 crores has to be regarded as one category and those companies cannot be regarded as comparables with companies having turnover of less than 200 crores
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