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2017 (5) TMI 971 - ITAT MUMBAITPA - selection of comparable - Held that:- As assessee is engaged in the business of providing Engineering consultancy services in the field of Chemicals, Petrochemicals, Fertilisers, Cement, Pharmaceuticals and allied industries, the companies with dis-similar functional activity need to be deselected from final list of comparable. The assessee followed TNMM method to benchmark the international transactions entered with its AEs. Government Companies cannot be taken as Comparable. There is merit in the contentions of the Ld A.R that the turnover filter of 1/4th to 4 times adopted by TPO was arbitrary in nature. Accordingly we direct the AO/TPO to adopt turnover filter at 1/10th to 10 times of turnover of the assessee and accordingly re-examine the comparables. Company with Related Party Transactions was more than 25% need to be excluded
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