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2022 (12) TMI 532 - AT - Income TaxTP Adjustment - determination of Arms’ Length Price (ALP) in respect of the international transaction of rendering SWD services to the AE - Comparable selection - turnover filter - HELD THAT:- We hold that the 7 companies listed whose turnover in the current year is more than Rs.200 Crores should be excluded from the list of comparable companies. TPO is directed to compute the ALP of the international transaction of rendering SWD services by the Assessee to its AE as per the directions contained in this order after affording opportunity of being heard to the Assessee.
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