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2019 (1) TMI 1689 - PUNJAB AND HARYANA HIGH COURTTP Adjustment - excluding M/s. Accentia Technologies Limited, M/s. Coral Hub (previously known as Vishal Information Technologies) and M/s. Eclerx Services Ltd. used as comparables for determining the arm's length price - HELD THAT:- The assessee-company is engaged in providing data collection, web services, information research and related support services to its associated enterprise (AE). Accentia Technologies Ltd. being functionally different and having extraordi nary events during the relevant year, cannot be considered as com parable to the assessee-company and accordingly, we direct the Assessing Officer/Transfer Pricing Officer to exclude the said com pany from the set of comparables. Coral Hub (previously known as Vishal Information Technologies Ltd. is engaged in different verticals and work through outsourcing models, thus being functionally different, cannot be considered as comparable to the assessee-company and accordingly we direct to exclude the said company from the set of comparables. M/s. Eclerx Services Ltd provided high value finan cial services relating to consultancy business and solution testing besides the web content management merchandising execution, web analytics, etc. This functional dissimilarity, and absence of segmental data led to its exclusion as a comparable. Those are findings of facts based upon record. Consequently, exclusion of E-Clerx was in order and cannot be interfered with.
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