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2019 (6) TMI 1180 - AT - Income TaxTP Adjustment - comparable selection - functional similarity - HELD THAT:- The assessee is engaged in research and development relating to software solutions. The assessee-company is a captive service provider to its US parent company. The assessee is having three units in India registered under Software Technology Park Scheme thus companies functionally dissimilar with that of assessee need to be deselected from final list. Selecting comparables turnover is an important filter. The company with exceptionally higher turnover cannot be compared with a company operating at smaller range.
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