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2019 (6) TMI 1670 - AT - Income TaxTP Adjustment - comparability analysis - determination of Arm’s Length Price (ALP) in respect of an international transaction of rendering Software Development Services (SWD services) by the Assessee to its Associated Enterprise (AE) i.e., its holding company Verisign Inc., US and Versign SARL - comparable selection - HELD THAT:- Infosys Ltd., Larsen & Toubro Infotech Ltd. and Persistent Systems Ltd. need to be deslected from comparable list when compared to assessee providing SWD services to its AE as relying on AGILIS INFORMATION TECHNOLOGIES INDIA PVT. LTD. (NOW KNOWN AS INFOGIX INTERNATIONAL PVT. LTD.) [2017 (11) TMI 908 - ITAT DELHI] Companies as functionally dissimilar with that of assessee as involved in providing SWD services to its AE need to be deselected from final list.
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