https://www.taxtmi.com/caselaws?id=329081 Transfer pricing comparability must be based on real functional similarity, including services performed, assets used and risks assumed, and a KPO cannot be treated as comparable to a lower-end BPO where the service profile is materially different; the existing analysis was therefore restored for fresh adjudication. Foreign exchange fluctuation gain directly linked to export activity was treated as part of business profits derived from the undertaking and was eligible for deduction under section 10A. The assessee obtained relief on both issues, with the transfer pricing matter remanded and the section 10A claim allowed on the exchange gain. en-us Wed, 18 May 2016 00:00:00 +0530 Wed, 22 Jun 2016 09:07:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=329081 Transfer pricing comparability must be based on real functional similarity, including services performed, assets used and risks assumed, and a KPO cannot be treated as comparable to a lower-end BPO where the service profile is materially different; the existing analysis was therefore restored for fresh adjudication. Foreign exchange fluctuation gain directly linked to export activity was treated as part of business profits derived from the undertaking and was eligible for deduction under section 10A. The assessee obtained relief on both issues, with the transfer pricing matter remanded and the section 10A claim allowed on the exchange gain. Case-Laws Income Tax Wed, 18 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=329081