1. Research and development services provider could not be compared to a company
2. Where segmental data relating to research operation of a company was not available, it could not be compared with assessee rendering research and development service.
3. Addition made by Assessing Officer on basis of order of TPO on account of interest on delay in realisation of dues from associate enterprises, was uncalled for as assessee had no interest liability and there was no interest cost to assessee
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