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2018 (5) TMI 1536 - ITAT BANGALORE
Determination of Arm’s Length Price in respect of international transaction of rendering of Software Development Services - comparability selection criteria - Held that:- Assessee is a company engaged in the business of providing contract Software Development Services (SWD Services) to its AE. The transaction of rendering software development services to its AE was an international transaction, thus companies functionally dissimilar with that of assessee need to be deselected from final list.