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2023 (1) TMI 1201 - ITAT PUNETP Adjustment - comparable selection - Functional dissimilarity - HELD THAT:- Assessee does Software development as per the basic design provided by its AEs. It is also mentioned in the TPSR that assessee also undertakes the design and other services in the entire Software development life cycle. Assessee also undertakes software coding, thus companies functionally dissimilar will be excluded.
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