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2016 (6) TMI 1265 - AT - Income TaxTPO - comparable selection criteria - Held that:- The functional profile of the assessee is to provide specified procurement services to its foreign company Adidas Consultants Ltd. The nature of services have been brought out at para 8.1 and 8.2 of that order. A perusal of these demonstration that the functional profile of M/s Chemical & Metallurgical Design Co.Ltd. are totally different from the functional profile of the assessee company. Thus this company should be excluded as a comparable company for determining the ALP. The TPO/AO is directed accordingly.
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