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2020 (2) TMI 724 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Assessee is engaged as captive software development support service provider to eGain, USA. The work done by the assessee belongs to the parent company. The assessee is remunerated at cost plus 10% markup. The only activity carried out by the assessee is that of rendering product software development services to its Associated Enterprise (AE), thus companies functionally dissimilar need to be deselected.
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