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2019 (11) TMI 1096 - AT - Income TaxTP Adjustment - adjustment made to the arm's length price of software development services provided to the overseas Associated Enterprises (AEs) - comparable selection - HELD THAT:- The assessee basically is engaged in providing software development services to the AE thus companies functionally dissimilar with that of assessee need to be deselected from final list. Company excluded who exceeds more than 25% RPT filter applied by the Transfer Pricing Officer.
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