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2019 (1) TMI 739 - AT - Income TaxTPA - assessee a wholly owned subsidiary of Virtusa Inc. USA, and derives income from providing software development and maintenance services to its parent company - comparable functionally - Held that:- The assessee is having turnover of 90.24 crores and turnover of Infosys Technologies Ltd. was ₹ 6860 crores, which is 76 times of assessee’s turnover. The comparison has to be on level playing. The basics of comparison are that of apple to apple, not apple with watermelon. Further, it has brand value and has also engaged in development of various niche products. Therefore we uphold the order of CIT(A) in directing to exclude big companies like Infosys Technologies Ltd. as comparable to the assessee company and accordingly, dismiss the grounds raised by the revenue in this regard. Appeal of the revenue is dismissed.
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