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2016 (12) TMI 1745 - AT - Income TaxTPA - Comparable selection criteria - functinal dissimilarity - Held that:- Appellant is purely engaged in the business of providing software development services to its parent company. Therefore, the companies functionally dissimilar shall be excluded from the list of comparables to determine the arm's length price in the appellant's case. TPO shall re-work the PLI after incorporating our findings with respect to comparables.
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