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2021 (7) TMI 756 - ITAT BANGALORETransfer pricing adjustments - providing product safety testing certification services and IT enabled services to its subsidiary/ associate enterprises situated at USA - HELD THAT:- With regard to Transfer Pricing adjustment made in respect of Certification Service Segment, an identical issue was examined by the co-ordinate bench in the assessee’s own case, and the matter was restored back to the file of AO/TPO with a set of directions for examining is afresh. - Matter restored back to the file of AO/TPO. TP adjustment made in respect of ITES segment. - selection of comparable - HELD THAT:- We notice that the co-ordinate bench has directed exclusion of M/s Infosys BPO Ltd and remanded the remaining four comparable companies to the file of AO/TPO. Consistent with the view taken in the above said case, we direct exclusion of M/s Infosys BPO Ltd and remand the remaining four comparable companies to the file of AO/TPO with similar directions. - Further, AP/TPO directed to include the M/s Crystal Voxx Ltd as a comparable company.
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