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2021 (2) TMI 846 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Exclusion of companies functionally not similar with that of assessee who provides software development services to its parent company and also if as they fail the turnover filter. Working capital adjustment on the average margin at 1.98% - HELD THAT:- Rule 10B(3) of the Income-tax Rules, 1962, supports the said action of the TPO in granting a working capital adjustment M/S. NTT DATA GLOBAL DELIVERY SERVICES LTD. [2016 (4) TMI 1221 - ITAT BANGALORE],M/S BEARING POINT BUSINESS CONSULTING PRIVATE LTD. [2014 (4) TMI 997 - ITAT BANGALORE] AND APIGEE TECHNOLOGIES (INDIA) PVT. LTD. [2015 (9) TMI 1547 - ITAT BANGALORE] it has been held that adjustment towards working capital differences between the assessee and the comparables should be considered and appropriate adjustment granted in arriving at the profit margins of comparable companies for the purpose of comparison.
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