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2023 (6) TMI 614 - AT - Income TaxTP adjustment - international transaction undertaken with overseas Associated Enterprise (AE) - Comparable selection - assessee is a resident corporate entity stated to be engaged in Airport Ground Handling Services for Lufthansa Airlines, providing services in pursuance to an agreement executed with the concerned AE - HELD THAT:- Exclude Container Corporation of India from the list of comparables as functionally dissimilar with that of assessee. Sanco Trans Limited - As no segmental accounts prepared by M/s Sanco Trans has earned total operating revenue of Rs.4296.36 lakh and total employee cost incurred is 511.96 lakhs which in ratio terms is 11.91%. This shows that this is also not a service-oriented company. Thus we hold that Sanco Trans Limited cannot be treated as comparable to the assessee.
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