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2023 (3) TMI 1086 - AT - Income TaxTP Adjustment - Comparable selection - HELD THAT:- Assessee in engaged in the business of provision of Information Technology enabled Services (ITeS), to its wholly owned holding company, thus companies functionally dissimilar with that of assessee need to be deselected. Application of turnover filter - We hold that 7 companies whose turnover in the current year is more than Rs.200 Crores should be excluded from the list of comparable companies - We direct the TPO/AO to compute the ALP of international transaction in question as per the directions contained in this order, after affording Assessee opportunity of being heard.
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