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2018 (5) TMI 515 - AT - Income TaxTransfer pricing addition - comparable selection criteria - functional similarity - Held that:- Assessee was engaged in the business of labor assisted assembly process of semi-conductor devices of different types which were mainly used in general power management applications. Semi-conductor manufacturing involved two phases of production-Wafer Fabrication and Assembly. The assessee was primarily an assembler of semi-conductor devices such as rectifiers, discrete and modules which were essentially low technology activity involving manual labor operations. Thus companies functionally dissimilar with that of assessee need to be deselected from final list.
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