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of The ITAT upheld the CIT(A)'s exclusion of several companies as comparables for transfer pricing adjustment due to functional dissimilarities, differing service portfolios, and failure to meet turnover and export earning filters. Companies engaged in high-end KPO services, software development, or possessing significant brand value were deemed functionally distinct from the assessee, an ITeS provider. The Tribunal noted that entities such as Acropetal Technologies Ltd., Accentia Technologies Ltd., ICRA Online Ltd., Infosys BPO Ltd., Jeevan Scientific Technology Ltd., and iGate Global Solutions Ltd. did not meet comparability criteria due to differences in business activities, service offerings, profitability fluctuations, or scale of operations. Consequently, the ITAT dismissed the revenue's appeal, affirming the CIT(A)'s exclusion of these companies from the comparable set for determining the arm's length price.
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