IT/ILT : Where TPO made addition to assessee's ALP in respect of software development services provided to its AE located abroad, in view of fact that some of comparables selected by TPO were also engaged in sales of software products and thus they were functionally different whereas some other comparables were found inappropriate on account of related party transactions, brand value, high turnover, etc., impugned adjustment was to be set aside and, matter was to be remanded back for disposal af
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