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Income Tax - Highlights / Catch Notes

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TP Adjustment - Comparable selection - TPO on his part has also ...

Income Tax

February 28, 2023

TP Adjustment - Comparable selection - TPO on his part has also adopted a filter whereby he has chosen companies having service income of 75% or more in each of the segments. We also notice that it has not been demonstrated as to how owning intangibles will render this company out of the ambit of comparability. In the given circumstances of the case, we are of the view that Concentrix was rightly included as a comparable company by the TPO. - AT

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