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2015 (9) TMI 1669 - AT - Income TaxTP Adjustment - international transaction with the Associated Enterprise (AE) on software development services - inclusion of certain comparable companies by the TPO to benchmark the profit margin of the assessee on such transactions - HELD THAT:- The assessee company is a subsidiary of Somero Enterprises Inc Mauritius, which in turn is a subsidiary of Dassault Systems France which is premier global software developer and product like Cycle Management Solutions. It is the holding company of Delmia Corporation, USA. The assessee was established as 100% export oriented Unit registered under STPI. It is mainly engaged in the provision of software developer and other related services primary to its group companies, thus companies functionally dissimilar with that of assessee need to be deselected.
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