2017 (7) TMI 1237

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... arms length price of the international transaction on account of functional dissimilarity when compared with the Assessee? Held that:- Having heard the learned counsel for the parties, the Court find that the ITAT has assigned clear and cogent reasons that the above entities should be excluded from the list of comparables. The findings are factual and based on proper analysis and does not give .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ngth price of the international transaction on account of functional dissimilarity when compared with the Assessee? 3. Having heard the learned counsel for the parties, the Court find that the ITAT has assigned clear and cogent reasons that the above entities should be excluded from the list of comparables. The findings are factual and based on proper analysis and does not give rise to any subs .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X