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2015 (5) TMI 390 - AT - Income TaxTransfer pricing adjustment - selection of comparable - Held that:- Tata Elxsi Ltd. (seg), Sasken Communication Technologies Ltd.,Persistent Systems Ltd., Zylog Systems Ltd.,Mindtree Ltd. (seg), Larsen & Toubro Infotech & Infosys Ltd. be excluded from the list of comparable as having turnover of more than ₹ 200 Crores from the list of comparables since the assessee's turnover was less than ₹ 200 Crores. Bodhtree Consulting Ltd to be excluded as functionally different. KALS Information Systems Ltd. to be excluded as this company was developing software products and not purely or mainly software development service provider. Flextronics Software Systems Ltd. ould be inappropriate to compare the business operations of the assessee with that of a company following hybrid business model comprising of royalty income as well as regular software services income, for which revenue break-up is not available
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