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2020 (5) TMI 459 - AT - Income TaxTP Adjustment - Comparable selection - HELD THAT:- NTPCESL is entirely provided work by its holding company, NTPC, and various projects and contracts are being awarded by Government companies/Departments and as such, is functionally dissimilar vis-à-vis the taxpayer. What has been discussed above, we are of the considered view that ld. DRP has rightly excluded NTPCESL as a comparable on ground of functional dissimilarity.
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