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2023 (9) TMI 1152 - AT - Income TaxTP Adjustment - Comparable selection - exclusion of Tata Elxsi and Mind Tree Ltd., from the final set of comparable companies on the basis of turnover filter exceeding more than Rs. 200 crores - HELD THAT:- We do not find Tata Elxsi and Mind Tree Ltd., and as such, there is no question of adjudicating these 2 comparables on the basis of turnover filter exceeding more than Rs. 200 crores. Issue regarding to inclusion of iSN Global Solution Pvt. Ltd., as comparable while determining the ALP of international transaction after considering the export turnover filters. Accordingly, this issue is remitted to the file of AO/TPO for fresh consideration.
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