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2019 (1) TMI 2038 - AT - Income TaxTP Adjustment - comparable selection - Info Edge (India) Ltd., Media Reserarch Users Council, MMTV LTD, Power Systems Operation Corpn. Ltd. and TSR Darashaw - HELD THAT:- From the annual reports of each of the comparables contested by the Revenue it can be seen that comparables are functionally dissimilar to the assessee company. These comparables are considered in case of Adobe Systems India Pvt. Ltd [2018 (7) TMI 741 - ITAT DELHI] for the same Assessment Year 2011-12 and from the perusal of the Tribunal’s order it can be seen that these comparables are functional different than assessee’s company. The assessee company is engaged in provisions of marketing support services to Teijin-Japan and other group companies, while the comparables are functionally different from the assessee companies which can be seen from the Annual reports of each of the comparables. The DRP has given proper direction for excluding these comparables contested by the Revenue. The Ld. DR also was not able to demonstrate that the functional profile of these comparables is similar to that of assessee company. Therefore, the appeal filed by the Revenue is dismissed
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