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2017 (3) TMI 1666 - AT - Income TaxTransfer pricing - Selection of comparables for international transaction of contract research and testing services - Held that:- Celestial Labs is not functionally comparable to the assessee as it is also in the field of research in pharmaceutical products and should be considered as comparable - AO has not followed the directions of the DRP fully - assessee is permitted to raise all the legal and factual issues before the DRP and may also submit the order of the Tribunal before the DRP for its consideration - DRP shall decide this issue afresh - appeal filed by the assessee is treated as allowed, for statistical purpose
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