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2018 (12) TMI 1609 - AT - Income TaxTransfer pricing adjustment - comparable selection - HELD THAT:- Assessee is a company engaged in the business of providing contract Software Development Services (SWD Services) and providing Information Technology Enabled Services (ITES) to its holding company Evolving Systems USA as a captive service provider. The transaction of rendering software development services to holding company was a transaction with an Associated Enterprise (AE) and was therefore an international transaction. Companies functionally dissimilar with that of assessee need to be deselected from final list of comparable. - Rule 10B Followed ITAT Delhi Bench decision in the case of Agilis Information Technologies India (P) Ltd. Vs. ACIT [2017 (11) TMI 908 - ITAT DELHI]
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