Taxpayers Can Exclude Entities from Comparables List if Functional Disparity Exists in Transfer Pricing Adjustments.

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....TP Adjustment - Selection of comparable - An inclusion of certain entity in the list of comparables by the assessee in transfer pricing study report cannot act as estoppel against the assessee if, at a later stage, assessee seeks exclusion of the said comparable on account of functional disparity or it fails to qualify any of the filters applied.....