https://www.taxtmi.com/caselaws?id=255267 Transfer pricing comparability requires functional similarity and financial results that reflect normal business conditions. In the software services segment, KALS Information Systems Ltd. was excluded because it was engaged in software products, while Bodhtree Consulting Ltd. was excluded due to highly fluctuating margins. In the ITES segment, Vishal Information Technologies Ltd., Accentia Technologies Ltd., Eclerx Services Ltd. and Cosmic Global Ltd. were excluded because of outsourced or intermediary models, extraordinary circumstances, or KPO-level functions that were not comparable to routine BPO services. Fresh search comparables proposed by the assessee required FAR-based reconsideration rather than rejection solely because they were not part of the original study. en-us Fri, 31 Oct 2014 00:00:00 +0530 Mon, 16 Feb 2015 14:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=255267 Transfer pricing comparability requires functional similarity and financial results that reflect normal business conditions. In the software services segment, KALS Information Systems Ltd. was excluded because it was engaged in software products, while Bodhtree Consulting Ltd. was excluded due to highly fluctuating margins. In the ITES segment, Vishal Information Technologies Ltd., Accentia Technologies Ltd., Eclerx Services Ltd. and Cosmic Global Ltd. were excluded because of outsourced or intermediary models, extraordinary circumstances, or KPO-level functions that were not comparable to routine BPO services. Fresh search comparables proposed by the assessee required FAR-based reconsideration rather than rejection solely because they were not part of the original study. Case-Laws Income Tax Fri, 31 Oct 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=255267