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2021 (1) TMI 1291 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Assessee is engaged in providing information technology enabled services ("ITES") to its holding company and therefore has to be regarded as an Associated Enterprises ("AEs"), thus companies functionally dissimilar with that of assessee need to be deselected. Also if filter of sales > Rs. 1 crore OR export turnover in excess of 75% of total sales is not satisfied exclusion of company as a comparable company confirmed. Also companies with huge brand value and diversified activities need to be deslected.
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