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2017 (6) TMI 1295 - AT - Income TaxTPA - comparable selection - functional dissimilarity - HELD THAT:- As the assessee before us is a provider of software services, the two concerns i.e. FCS Software Solutions Ltd. and Infosys Technologies Ltd. have to be excluded from the final set of comparables as they are functionally not comparable. CAT Technologies Ltd. and RS Software (India) Ltd. - Any concern is to be included in the final set of comparables, where it satisfied the filter of more than 75% of earning from exports.
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