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2018 (7) TMI 2061 - AT - Income TaxTP Adjustment - determination of Arm’s Length Price (ALP) in respect of an international transaction entered into by the assessee with its Associated Enterprise (AE) - Comparable selection - HELD THAT:- Assessee company is providing software development service , thus companies functionally dissimilar with that of assessee need to be deselected from final list. Working capital adjustment - TPO computed the adjustment on account of working capital at 2.54%. He, however, restricted working capital adjustment only to a sum of 1.63% - HELD THAT:- As relying on ZYME SOLUTIONS P. LTD.[2016 (6) TMI 1375 - ITAT BANGALORE] we hold that working capital adjustment has to be allowed at 2.54% as computed by the TPO and cannot be restricted to 1.63% as done by the TPO.
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