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2017 (7) TMI 1193 - AT - Income TaxTPA - Comparable selection - Held that:- From the profile of the taxpayer as recorded by the TPO himself in his order, the assessee is into simple ITES services. Except for arguing that the assessee is also into KPO services, the Ld DR has not been able bring on record any material to rebut the findings of the DRP. Thus companies functionally dissimilar with that of assessee need to be deselected from list. Computing the interest on receivables - Held that:- As relying on Income Tax Officer vs. Nevis Network (India) (P.) Ltd [2015 (4) TMI 722 - ITAT PUNE] assessee has placed a working regarding the difference in time lag in sale recoveries in the case of the assessee and that of the three comparable concerns selected by the TPO. The difference in such time lag is applied to the Prime Lending Rate (PLR) to compute the working capital adjustment. On this basis, an adjustment of 5.90% was determined, which was required to be applied to the operating margins of the three comparable concerns. The CIT (A), in our view, made no mistake in accepting the plea of the assessee for allowing of such working capital adjustment. The said action of the CIT (A), in our view, is liable to be affirmed. We hold so
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