Comparables dissimilar in Functionally & Turnover cannot be included by TPO

Agilent Technologies India Pvt. Ltd Vs DCIT (ITAT Delhi) With respect to the Infosys technologies it is the claim of the assessee that the turnover of the above company is such a huge turnover that it is not comparable with the assessee company is software development division. For this proposition we look at page number 165 of the paper book wherein the software development division revenue of the assessee is only Rs.16.80 crores whereas the turnover of the comparable company i.e. Infosys technologies Ltd compared by the learned transfer pricing officer is ₹ 21,140 crores. It is also submit...