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of Tribunal held that Vishal Information Technologies Ltd. and Nucleus Net soft & GIS (India) Ltd. should be excluded from comparable selection for determining arm's length price of international transactions. Vishal Information Technologies Ltd. engaged in data conversion, digitization of documents, text conversion, and e-publishing, functionally different from assessee providing voice, communication, data entry, and financial management services. Nucleus Net soft & GIS Ltd. excluded due to different business model, export revenue filter, extraordinary events, and lack of segmental details. Company outsourced most business activities with major operating expenses for data processing charges, unlike assessee. Extraordinary event of amalgamation approved by Bombay High Court. Company had IT and ITeS segments considered as one without separate segmental details available. Therefore, these companies not comparable to assessee for transfer pricing adjustment.
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