Functionally dissimilar comparable cannot be included

Samsung India Electronics Pvt. Vs Addl. CIT (ITAT Delhi)

OTS E-Solutions Pvt. Ltd.: From the perusal of the records it can be seen that OTS E-Solutions Pvt. Ltd. was held as not comparable in subsequent assessment year i.e. A.Y. 2014-15 by the Tribunal. The functional dissimilarity is apparent on record and there are no changes in the present assessment year. Hence, we direct the TPO to exclude this comparable from the final list of comparables.

Celkon Impex Pvt. L

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