https://www.taxtmi.com/caselaws?id=330940 Functional comparability in BPO transfer pricing requires testing the real nature of services, business model, scale and outsourcing structure; entities engaged in high-end or materially different services were excluded as dissimilar, while some comparables were remitted for fresh consideration. Royalty could not be valued at nil merely on a benefit-test or perceived commercial wisdom; absent proper benchmarking and comparable uncontrolled data, nil arm's length pricing was unsustainable and required fresh examination. Prior period expenses depended on whether the liability had crystallised during the year, so the claim was restored for verification of bills and accrual timing. en-us Tue, 05 Jul 2016 00:00:00 +0530 Mon, 08 Aug 2016 12:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=330940 Functional comparability in BPO transfer pricing requires testing the real nature of services, business model, scale and outsourcing structure; entities engaged in high-end or materially different services were excluded as dissimilar, while some comparables were remitted for fresh consideration. Royalty could not be valued at nil merely on a benefit-test or perceived commercial wisdom; absent proper benchmarking and comparable uncontrolled data, nil arm's length pricing was unsustainable and required fresh examination. Prior period expenses depended on whether the liability had crystallised during the year, so the claim was restored for verification of bills and accrual timing. Case-Laws Income Tax Tue, 05 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=330940