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Ground of appeal of the assessee is that on the facts and in the circumstances of the case, the Ld. CIT(A), the Ld. Transfer Pricing Officer (TPO) and the Ld. Assessing Officer (A.O), erred in making adjustment of Rs.2,34,30,468/- to the total income of the Appellant in respect of international transactions entered into by the Appellant with its Associated Enterprises.

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Sec. 92C of Income Tax Act, 1961—Transfer Pricing—Selection of comparables - comparable engaged in providing computer related activities like maintenance of website for its clients, creation of multimedia presentation of its client. is not functionally comparable with the software development services of assessee, therefore, Assessing Officer was directed to exclude this comparable from final set of comparable; comparable with high turnover filter to be excluded - XORIANT SOLUTIONS (P.) LTD. V/s ITO - [2020] 183 ITD 180 (ITAT-MUMBAI)
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