2013 (4) TMI 486

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.... JUDGMENT:- 1. In this appeal by the Revenue for assessment year 2007-08, following reframed questions of law have been proposed for our consideration. "(a) Whether on the facts and circumstances of the case, the Tribunal was correct in holding that comparable selected by the TPO were not functionally comparable while determining ALP ? (b) Whether on the facts and circumstances of the ca....

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....essee was not accepted. The Tribunal by the impugned order held that the eight comparables other than M/s. IDC (India) Limited were not functionally comparable with the respondent and, therefore, could not be relied upon. The counsel for the Revenue states that for the subsequent assessment years, assessing officer has found that the eight comparables selected by the TPO were not functionally comp....