https://www.taxtmi.com/caselaws?id=190921 Transfer pricing comparability findings on functional similarity, related party transaction filters, and segmental data are ordinarily factual and will not be disturbed in section 260A appeals unless perverse. Rule 10B(4) requires comparability to be based on the same financial year as the tested transaction, so a mismatched accounting period can justify exclusion. The commentary also notes that software product companies may be dissimilar to service providers, KPO/LPO profiles may not be comparable to BPO services, and mixed-activity entities may still be accepted where the BPO segment predominates on the record. The Revenue's challenge was therefore rejected and the Tribunal's directions remained undisturbed. en-us Mon, 26 Sep 2016 00:00:00 +0530 Wed, 23 Jul 2025 14:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=190921 Transfer pricing comparability findings on functional similarity, related party transaction filters, and segmental data are ordinarily factual and will not be disturbed in section 260A appeals unless perverse. Rule 10B(4) requires comparability to be based on the same financial year as the tested transaction, so a mismatched accounting period can justify exclusion. The commentary also notes that software product companies may be dissimilar to service providers, KPO/LPO profiles may not be comparable to BPO services, and mixed-activity entities may still be accepted where the BPO segment predominates on the record. The Revenue's challenge was therefore rejected and the Tribunal's directions remained undisturbed. Case-Laws Income Tax Mon, 26 Sep 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=190921