TPO can’t include functionally different Companies in comparables for transfer pricing adjustment

ITAT BANGALORE BENCH ‘B’ Google India (P.) Ltd. Versus Deputy Commissioner of Income tax IT APPEAL NO. 1368 (BANG.) OF 2010 [Assessment year 2006-07] OCTOBER 19, 2012 ORDER Smt. P. Madhavi Devi, Judicial Member  This appeal is filed by the assessee. The relevant assessment year is 2006-07. The appeal is directed against the assessment order passed in consonance with the order of the Dispute Resolution Panel at Bangalore dated 20.09.2010. The appeal arises out of the assessment completed u/s 144C(5) r.w.s 144C(8) of the Income-tax Act, 1961. 2. The assessee is agg...