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2018 (11) TMI 1169 - ITAT DELHITPA - selection of comparable - functinal dissimilarity - Held that:- Assessee is a company engaged in the business of rendering IT enabled services ( ITES) in the nature of data management services (i.e. data management services, data collection, organization, validation, analysis and filtering of accounts) and call center services to its overseas associated enterprise (AE) thus companies functionally dissimilar with that of assessee need to be deselected from final list. Also on the huge brand value and the huge asset base of intangible assets need to be rejected.
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