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2015 (12) TMI 1660 - AT - Income TaxTPA - selection of comparable - Held that:- As gone through the Master Services Agreement between the assessee and its AE, namely, Tech Enterprises Inc., a Fairfax based incorporation having its registered office at Fairfax, Virginia, USA. This Agreement is valid for the year under consideration as well, whose copy is available at page 263 onwards of the paper book. As per this Agreement, the assessee specializes in provision of technical services, such as, data conversion, web-page construction, data entry/key boarding and software development. The assessee under this Agreement has undertaken to render ‘Included services’ which have been described in Exhibit-A. The services so availed by the assessee’s AE are ultimately given to end-customers. Thus companies dissimilar with that of assessee need to be excluded from final list of comparability.
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