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    <description>Transfer pricing comparables in an investment advisory business must be selected on true functional similarity; entities engaged in engineering design, data processing or high-end analytics were held unsuitable, and the comparable set was directed to be recomputed with appropriate inclusions and exclusions. A provision for legal and professional fees was not disallowable where the liability was subsequently paid and subjected to tax withholding, so the disallowance was deleted. Travelling and conveyance expenses depended on supporting particulars and genuineness, and the matter was remitted for fresh verification after giving the assessee an opportunity to produce evidence.</description>
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