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2023 (2) TMI 1118 - HC - Income TaxTP Adjustment - Comparable selection - exclusion of Certification Engineering International Ltd., HSCC India Ltd. and Mitcon Consultancy & Engineering Services Ltd. - HELD THAT:- ITAT excluded Certification Engineering International Ltd. and HSCC India Ltd. not only on the ground that these companies were government undertaking, but also on ground of functional dissimilarities with the assessee company. The ITAT excluded the Mitcon Consultancy & Engineering Services Ltd. on the ground of functional dissimilarity with the assessee company as well on the ground that the same comparable was excluded by ITAT in assessee’s own case for the AY 2011-12, and the said order of the ITAT was confirmed by this Court [2019 (7) TMI 1147 - DELHI HIGH COURT]
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