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2019 (9) TMI 658 - AT - Income TaxTP Adjustment - assessee used TNMM as most appropriate method and OP/OC as PLI and determined margin to be 15% for software and hardware development service segment - HELD THAT:- Assessee provides software and hardware development services to NI U.S., operating as an independent contractor. The foreign AE compensates assessee on cost plus markup basis for services rendered in accordance with agreement entered into between assessee and NI US, thus companies functionally dissimilar with that of assessee need to be deselected from final list.
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