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2022 (3) TMI 1476 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Rejection of companies non-comparable to assessee's international transaction of Information Technology Enabled Services. We noticed that the Cosmic Global Limited was excluded from the comparables in the earlier Assessment Years and the Coordinate Benches consistently confirmed the same. The major part of the income is from translation charges and functions of this comparable is different to the assessee company, therefore consistent with the earlier assessment year, we also direct the Assessing Officer/TPO to exclude this company from the list of comparables. We direct the AO/TPO to exclude the comparable E-Clerx Services Ltd., and Coral Hubs Ltd., from the list of comparables as substantially different from that of the assessee.
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