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2017 (2) TMI 1438 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Companies functionally dissimilar with that of assessee providing software development services to the AE need to be deselected from final list. Risk adjustment - It is seen from the observations of the TPO that the TPO is not against risk adjustment but it was not allowed for the reason of absence of proper basis of quantification. Now, that the assessee has given the basis of such quantification, the TPO /AO is directed to consider them in the light of this Tribunal decisions.
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