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2020 (5) TMI 211 - AT - Income TaxTP Adjustment - comparable selection - Functional dissimilarity - HELD THAT:- Main function performed by assessee, is in respect of R&D functions, wherein assessee focuses on developing existing technologies for direct customer application. Assessee has been characterised to be working on a risk mitigated environment on a contract basis strictly providing services, as per needs/requirements of associated enterprise, thus companies functionally dissimilar with that of assessee need to deselected from final list.
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