https://www.taxtmi.com/caselaws?id=256944 Transfer pricing comparability under TNMM must be based on functional similarity and reliable public-domain data. A captive software development services provider was distinguished from entities engaged in software product development, application support, infrastructure management, e-learning, SAP consulting, onsite services, or other materially different business models, leading to exclusion or inclusion of specific comparables on that basis. Loss by itself was not treated as a valid exclusion criterion absent abnormal circumstances or persistent losses, and software testing, verification and validation was treated as part of the software development process. A turnover-based filter introduced without prior notice or stated basis was held to require fresh consideration after hearing. en-us Wed, 11 Feb 2015 00:00:00 +0530 Tue, 24 Feb 2015 15:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=256944 Transfer pricing comparability under TNMM must be based on functional similarity and reliable public-domain data. A captive software development services provider was distinguished from entities engaged in software product development, application support, infrastructure management, e-learning, SAP consulting, onsite services, or other materially different business models, leading to exclusion or inclusion of specific comparables on that basis. Loss by itself was not treated as a valid exclusion criterion absent abnormal circumstances or persistent losses, and software testing, verification and validation was treated as part of the software development process. A turnover-based filter introduced without prior notice or stated basis was held to require fresh consideration after hearing. Case-Laws Income Tax Wed, 11 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=256944