https://www.taxtmi.com/caselaws?id=257373 Transfer pricing comparability for a captive software development service provider turned on functional similarity, intangibles, scale of operations and revenue profile. Software product companies and enterprises with significant brand value or other commercial advantages were treated as not comparable, leading to exclusion of Bodhtree Consulting Ltd., Infosys Ltd., KALS Information Systems Ltd. and Tata Elxsi Ltd. Certain other comparables and requested inclusions were remitted for fresh factual examination where the record was incomplete. The foreign tax credit claim was also restored for reconsideration, and the interest and tolerance-range directions were applied in the assessee's favour for statistical purposes. en-us Fri, 13 Feb 2015 00:00:00 +0530 Fri, 27 Feb 2015 15:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=257373 Transfer pricing comparability for a captive software development service provider turned on functional similarity, intangibles, scale of operations and revenue profile. Software product companies and enterprises with significant brand value or other commercial advantages were treated as not comparable, leading to exclusion of Bodhtree Consulting Ltd., Infosys Ltd., KALS Information Systems Ltd. and Tata Elxsi Ltd. Certain other comparables and requested inclusions were remitted for fresh factual examination where the record was incomplete. The foreign tax credit claim was also restored for reconsideration, and the interest and tolerance-range directions were applied in the assessee's favour for statistical purposes. Case-Laws Income Tax Fri, 13 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=257373