https://www.taxtmi.com/caselaws?id=246956 In transfer pricing comparability analysis, a company accepted by both sides as functionally comparable cannot be excluded at the appellate stage without a specific challenge and reasons, because the appellate role is adjudicatory and not revisional. Turnover alone is not a determinative basis for exclusion where functional similarity in a service-sector analysis is otherwise established; comparability must be assessed primarily on functions performed, assets employed and risks assumed. On that basis, Mercury Outsourcing Management Ltd., Wipro BPO Solutions Ltd. and Spanco Telesystems & Solutions Ltd. were to be retained or included as comparables, and the transfer pricing adjustment was to be recomputed accordingly. en-us Thu, 31 Oct 2013 00:00:00 +0530 Mon, 30 Mar 2015 11:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=246956 In transfer pricing comparability analysis, a company accepted by both sides as functionally comparable cannot be excluded at the appellate stage without a specific challenge and reasons, because the appellate role is adjudicatory and not revisional. Turnover alone is not a determinative basis for exclusion where functional similarity in a service-sector analysis is otherwise established; comparability must be assessed primarily on functions performed, assets employed and risks assumed. On that basis, Mercury Outsourcing Management Ltd., Wipro BPO Solutions Ltd. and Spanco Telesystems & Solutions Ltd. were to be retained or included as comparables, and the transfer pricing adjustment was to be recomputed accordingly. Case-Laws Income Tax Thu, 31 Oct 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=246956