Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Comparable selection for transfer pricing adjustment in the Information Process Management (IPM) segment was examined. UB Engineering Ltd. with negative operating margin of 46.58% was rejected as profitability is not a criteria, and future years' data was considered. Holtec Consulting Pvt. Ltd. and Neil Soft Ltd. were excluded as their functionality differed from the assessee, an Engineering, Procurement, and Construction (EPC) company. Info Edge India Ltd., an online search portal with substantially higher turnover, was rejected due to failing the Functional Asset Risk (FAR) test. The assessee's appeal was partly allowed, upholding certain comparables while rejecting others based on functional dissimilarities and FAR analysis.
Comparable selection for transfer pricing adjustment in the Information Process Management (IPM) segment was examined. UB Engineering Ltd. with negative operating margin of 46.58% was rejected as profitability is not a criteria, and future years' data was considered. Holtec Consulting Pvt. Ltd. and Neil Soft Ltd. were excluded as their functionality differed from the assessee, an Engineering, Procurement, and Construction (EPC) company. Info Edge India Ltd., an online search portal with substantially higher turnover, was rejected due to failing the Functional Asset Risk (FAR) test. The assessee's appeal was partly allowed, upholding certain comparables while rejecting others based on functional dissimilarities and FAR analysis.
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