Transfer pricing adjustment upheld for excluding non-comparable companies, remanded for fresh adjudication on certain issues.

TP adjustment affirmed for excluding Universal Print Systems Limited and BNR Udyog Limited as functionally dissimilar comparables. Vama Industries Ltd. excluded as not functionally comparable for IT services. Remanded to TPO to explain margin computation of 28.17% for Thirdware Solutions Ltd. and reconsider inclusion after providing opportunity of hearing to assessee. ITAT remanded certain comparability issues to TPO for fresh adjudication. .....

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