ITAT excludes six companies from transfer pricing comparables for software development services on functional dissimilarity grounds

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....ITAT ruled on transfer pricing comparable selection for appellant engaged in software development services to associated enterprise on cost-plus markup basis. Tribunal excluded six companies from comparables: Tata Elxsi Limited due to diversified activities including animation/VFX services creating functional dissimilarity; Persistent Systems Limited for functional dissimilarity and being giant company; Aspire Systems for extraordinary amalgamation event and turnover filter; Infosys Limited as captive service provider incomparable to appellant's cost-plus model; Thirdware Solutions for functional differences and intangible asset ownership; Cybage Software for providing different services. However, Larsen & Toubro Infotech Limited and Infobe.........