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2019 (1) TMI 952 - ITAT DELHITransfer pricing addition - comparable selection criteria - functional similarity - Held that:- As assessee is characterised as performing engineering design services as a sub contractor to Fluor Affiliate, exposed to limited risk associated with carrying out such business,0 thus companies functionally dissimilar with that of assessee need to be deselected from final list. If difference arising on comparability analysis does not affect price or profitability of comparable, or if it can be reasonably adjusted, same should be taken as good comparable for Comparability analysis. Therefore, it should not be assumed that, if a comparable is held to be excludible in one case, it shall always be excluded in decisions to follow subsequently. Thus, while deciding comparability, decisions cited definitely would be perused from this angle by us.
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