Held that companies with functional dissimilarity should be excluded. Unique intangible from which it could derive substantial benefit when compared to the assessee to be excluded. (AY.2010-11)
Dy. CIT v. Altisource Business Solutions P. Ltd. (2021) 88 ITR 135 (Bang.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Comparables-Functional dissimilarity-Excluded. [S. 92CA]