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2018 (3) TMI 1932 - AT - Income TaxTP Adjustment - comparable selection - functional dissimilarity - HELD THAT:- Companies functional un-comparable with software development services rendered by the assessee need to be deselected. Market risk adjustment - As assessee has given the details of marketing risk undertaken by the assessee as well as by the comparable. However the DRP / TPO has not considered the same. In view of the above, we direct the TPO to examine the market risks / risk adjustment of the assessee as well as the comparable in view of the details submitted by the comparable.
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