https://www.taxtmi.com/caselaws?id=260396 In transfer pricing analysis under the transactional net margin method, comparability must rest on functional similarity and reliable data. Companies showing abnormal profit trends may be excluded where those figures do not reflect normal business conditions, and entities lacking adequate segmental data are not suitable comparables. On that basis, Bodhtree Consulting Ltd. was rejected because of wide margin fluctuations, and E-Infochip Bangalore Ltd. was rejected because its combined software and IT-enabled services segment lacked proper segmental disclosure. The arm's length price was therefore required to be recomputed after excluding those comparables, with the adjustment restored for fresh determination. en-us Fri, 05 Jun 2015 00:00:00 +0530 Thu, 11 Jun 2015 06:21:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=260396 In transfer pricing analysis under the transactional net margin method, comparability must rest on functional similarity and reliable data. Companies showing abnormal profit trends may be excluded where those figures do not reflect normal business conditions, and entities lacking adequate segmental data are not suitable comparables. On that basis, Bodhtree Consulting Ltd. was rejected because of wide margin fluctuations, and E-Infochip Bangalore Ltd. was rejected because its combined software and IT-enabled services segment lacked proper segmental disclosure. The arm's length price was therefore required to be recomputed after excluding those comparables, with the adjustment restored for fresh determination. Case-Laws Income Tax Fri, 05 Jun 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=260396