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2022 (2) TMI 1353 - AT - Income TaxTP Adjustment - comparable selection - application of turnover filter - HELD THAT:- As decided in AUTODESK INDIA PRIVATE LTD [2018 (7) TMI 1862 - ITAT BANGALORE] high turnover is a ground for excluding companies as not comparable with a company that has low turnover. Seven companies listed in ground raised by the Assessee whose turnover in the current year is more than ₹ 200 Crores should be excluded from the list of comparable companies. TPO/AO is directed to compute the ALP of the international transaction of rendering of SWD services by the Assessee to AE in the light of the directions given above, after affording Assessee opportunity of being heard.
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