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    <title>2026 (1) TMI 682 - ITAT BANGALORE</title>
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    <description>No justification was found for alleged functional dissimilarity between selected comparables and the assessee; comparability required Functions, Assets &amp; Risk analysis which was not undertaken, and mechanical reliance on coordinate-bench decisions was rejected, resulting in nonconformity with law. Three high-turnover companies submitted as comparables were directed to be excluded from comparability analysis for lack of parity with the assessees turnover. One comparable (Harton Communications Ltd.) is to be investigated and verified for comparability and the matter remitted to the lower authority for fresh findings where the appellate authority failed to address the assessees objections. Appeal partly allowed.</description>
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      <description>No justification was found for alleged functional dissimilarity between selected comparables and the assessee; comparability required Functions, Assets &amp; Risk analysis which was not undertaken, and mechanical reliance on coordinate-bench decisions was rejected, resulting in nonconformity with law. Three high-turnover companies submitted as comparables were directed to be excluded from comparability analysis for lack of parity with the assessees turnover. One comparable (Harton Communications Ltd.) is to be investigated and verified for comparability and the matter remitted to the lower authority for fresh findings where the appellate authority failed to address the assessees objections. Appeal partly allowed.</description>
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