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2018 (4) TMI 1621 - AT - Income TaxDisallowance of deduction u/s 10B - Held that:- Since in the year under consideration also the assessee has made alternative claim for allowing deduction under section 10A of the Act, we, therefore, respectfully restore the matter to the file of the Assessing Officer for examining the claim of the assessee for allowing deduction under section 10A of the Act. It is needless to mention that assessee shall be afforded adequate opportunity of being heard. Accordingly, relevant grounds of the appeal are allowed for statistical purposes. Transfer pricing adjustment - Comparability analysis - Held that:- Assessee has rendered services of the analysis of the projects and entering those details into the tracker and deliver the final output to its AE. Thus, assessee can be characterized as engaged in providing “High-end ITes services" thus companies functionally dissimilar with that of assessee need to be deselected from final list. Also the company to be excluded on the ground of extraordinary event of amalgamation.
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