https://www.taxtmi.com/caselaws?id=254269 Transfer pricing comparability disputes concerned selection and exclusion of several software-sector comparables and allowance of market risk adjustment. The tribunal held that a company included solely on information gathered without furnishing it to the taxpayer is vitiated and must be excluded as functionally dissimilar, so exclusion followed. Companies with product development, proprietary software, significant R&D/IPR, or KPO services were held functionally dissimilar and excluded. One comparable was retained where functional profile and fluctuating margins did not prove dissimilarity. The tribunal remitted the question of market risk adjustment to the TPO/AO for appropriate allowance and recalculation. en-us Thu, 28 Nov 2013 00:00:00 +0530 Mon, 02 Feb 2026 14:32:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=254269 Transfer pricing comparability disputes concerned selection and exclusion of several software-sector comparables and allowance of market risk adjustment. The tribunal held that a company included solely on information gathered without furnishing it to the taxpayer is vitiated and must be excluded as functionally dissimilar, so exclusion followed. Companies with product development, proprietary software, significant R&D/IPR, or KPO services were held functionally dissimilar and excluded. One comparable was retained where functional profile and fluctuating margins did not prove dissimilarity. The tribunal remitted the question of market risk adjustment to the TPO/AO for appropriate allowance and recalculation. Case-Laws Income Tax Thu, 28 Nov 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=254269