ITAT Upholds Exclusion of Non-Comparable Companies in Transfer Pricing Under Section 92C

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....The ITAT upheld the CIT(A)'s exclusion of several companies as comparables for transfer pricing adjustment due to functional dissimilarities, differing service portfolios, and failure to meet turnover and export earning filters. Companies engaged in high-end KPO services, software development, or possessing significant brand value were deemed functionally distinct from the assessee, an ITeS provider. The Tribunal noted that entities such as Acropetal Technologies Ltd., Accentia Technologies Ltd., ICRA Online Ltd., Infosys BPO Ltd., Jeevan Scientific Technology Ltd., and iGate Global Solutions Ltd. did not meet comparability criteria due to differences in business activities, service offerings, profitability fluctuations, or scale of operati.........