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2021 (11) TMI 1151 - AT - Income TaxTP Adjustment - Comparable selection for “Mapping Segment” - HELD THAT:- Infosys BPM Ltd. comparable doesn’t meet the FAR profile with the assessee. Hence, we direct it to be deleted from the final list of comparable. Dun & Bradstreet Technology and Data Services Pvt. Ltd.specializes in providing Predictive Analytics, Decision Management and In formation Management platforms and services to Dun & Bradstreet and its clients globally. Value added services by the company are Predictive analytics, Risk management, Rating and scoring, Business intelligence and SME banking, thus the functional profile of the assessee matches with that of the comparable cannot be affirmed. Nihilent Analytics Limited has developed and been awarded a patent for Change Management based on MC3 ® framework for Performance Management and Strategy Execution. Nihilent also has a patent for its predictive ‘Customer Loyalty Evaluation’. We find that the companies primarily rendering software services and doesn’t hold any inventory. We have gone through the record before us and find that the ld. DRP has rightly allowed the inclusion of this comparable subjected to the availability of the accounts and passing of the filters. Hence, we decline to interfere with the order of the ld. DRP on this issue.
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