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2017 (12) TMI 921 - AT - Income TaxTPA - selection of comparable - Held that:- Assessee is a company engaged in the business of designing of semi conductor products, software and electronic systems and providing sales and technical support services. It is providing services to its Associated Enterprise and is wholly owned subsidiary of Freescale Semiconductor Inc. USA. It has a Software Technology Park Unit at Noida and Bangalore, thus companies functionally dissimilar with that of assessee need to be deselected from final list. Appeal filed by the assessee is partly allowed with respect to comparables in software development segment directing ld TPO /AO a. to exclude Infosys Limited and b. to examine the claim of the assessee with respect to exclusion of Bodhtree consulting Limited c. To reexamine the claim of the assessee of Sonata Sonata Software limited not passing the filter of related party transactions d. To not to compute the margins of Software development segments as well market support services as per safe harbor Rules but as per prevalent judicial precedents
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