https://www.taxtmi.com/caselaws?id=177140 Transfer pricing comparability in software development service cases was addressed by applying a turnover filter, related party transactions filter and functional comparability tests. Companies with turnover exceeding Rs. 200 crores were treated as unreliable comparables against a much smaller taxpayer and excluded. The Tribunal also held that related party transactions do not automatically disqualify a comparable, but a 15% threshold applies; companies above that level were excluded, while those below it could be retained. Functionally different companies, and high profits without extraordinary circumstances, did not justify exclusion. The 5% range under section 92C(2) was held to be a tolerance band only, not a standard deduction. en-us Fri, 19 Sep 2014 00:00:00 +0530 Mon, 04 Jan 2016 12:58:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=177140 Transfer pricing comparability in software development service cases was addressed by applying a turnover filter, related party transactions filter and functional comparability tests. Companies with turnover exceeding Rs. 200 crores were treated as unreliable comparables against a much smaller taxpayer and excluded. The Tribunal also held that related party transactions do not automatically disqualify a comparable, but a 15% threshold applies; companies above that level were excluded, while those below it could be retained. Functionally different companies, and high profits without extraordinary circumstances, did not justify exclusion. The 5% range under section 92C(2) was held to be a tolerance band only, not a standard deduction. Case-Laws Income Tax Fri, 19 Sep 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=177140