https://www.taxtmi.com/caselaws?id=245443 Under TNMM transfer pricing analysis, comparability must be assessed by functions performed, assets employed and risks assumed under section 92C read with Rule 10B. Captive ITES or back office support providers performing low-end processing work are not comparable with entities engaged mainly in high-end KPO services requiring specialised domain expertise, so the KPO comparables were excluded. By contrast, a company is not excluded merely because it earns a high profit margin; unusually high profitability only calls for closer scrutiny, and a comparable may still be retained if it is otherwise functionally similar and its results arise from normal business conditions. The assessee succeeded on exclusion of the KPO entities, while the broader challenge to high-profit comparables was not accepted as a blanket rule. en-us Fri, 07 Mar 2014 00:00:00 +0530 Tue, 29 Jul 2025 15:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=245443 Under TNMM transfer pricing analysis, comparability must be assessed by functions performed, assets employed and risks assumed under section 92C read with Rule 10B. Captive ITES or back office support providers performing low-end processing work are not comparable with entities engaged mainly in high-end KPO services requiring specialised domain expertise, so the KPO comparables were excluded. By contrast, a company is not excluded merely because it earns a high profit margin; unusually high profitability only calls for closer scrutiny, and a comparable may still be retained if it is otherwise functionally similar and its results arise from normal business conditions. The assessee succeeded on exclusion of the KPO entities, while the broader challenge to high-profit comparables was not accepted as a blanket rule. Case-Laws Income Tax Fri, 07 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=245443