https://www.taxtmi.com/caselaws?id=174826 Comparables used in transfer pricing benchmarking must satisfy the adopted related party transaction filter on a correct base, be functionally similar, and rely on data for the relevant financial year; on those grounds, several comparables in the IT services segment were found unsuitable and the arm's length price was directed to be reworked. In the IT-enabled services segment, some comparables were remitted or excluded for similar reasons, including higher-end KPO/LPO characteristics and intermediary business models, while other comparables were retained where dissimilarity was not established. The objection that no transfer pricing adjustment could survive because the assessee's income was exempt under section 10A was rejected, as the transfer pricing regime operates independently of that exemption. en-us Tue, 30 Apr 2013 00:00:00 +0530 Thu, 11 May 2017 09:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=174826 Comparables used in transfer pricing benchmarking must satisfy the adopted related party transaction filter on a correct base, be functionally similar, and rely on data for the relevant financial year; on those grounds, several comparables in the IT services segment were found unsuitable and the arm's length price was directed to be reworked. In the IT-enabled services segment, some comparables were remitted or excluded for similar reasons, including higher-end KPO/LPO characteristics and intermediary business models, while other comparables were retained where dissimilarity was not established. The objection that no transfer pricing adjustment could survive because the assessee's income was exempt under section 10A was rejected, as the transfer pricing regime operates independently of that exemption. Case-Laws Income Tax Tue, 30 Apr 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=174826