Functionally different company cannot be included in List of Comparables

SAP Labs India Pvt. Ltd. Vs DCIT (ITAT Bangalore)

The argument of the learned AR is that Infosys Limited is functionally different from the assessee. It owns intangible and undertakes research and development. The learned AR also submitted that it has high brand value and turnover. On the contrary, the learned DR submitted that the nature of services remains the same irrespective of whether it is engaged in providing onsite / offsite services.

In the present case also, Infosys Limited is engaged in a

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