https://www.taxtmi.com/caselaws?id=192622 Under TNMM with OP/TC as the profit level indicator, comparability must rest on functional similarity, not on quantitative filters alone. Companies were treated as unsuitable where they had different business models, owned strong brands or proprietary products, incurred heavy R&D or marketing spend, operated at much larger scale, or were affected by acquisitions, mergers or restructuring. Mixed product-and-service businesses were also excluded where segmental data was unavailable. Applying these principles, the note records exclusion of several software development and IT-enabled services comparables, including entities with brand advantages, product development activity, extraordinary events, or unreliable segmental results, leading to a reduced transfer pricing adjustment for the assessee. en-us Thu, 12 May 2016 00:00:00 +0530 Thu, 08 Jun 2017 05:56:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=192622 Under TNMM with OP/TC as the profit level indicator, comparability must rest on functional similarity, not on quantitative filters alone. Companies were treated as unsuitable where they had different business models, owned strong brands or proprietary products, incurred heavy R&D or marketing spend, operated at much larger scale, or were affected by acquisitions, mergers or restructuring. Mixed product-and-service businesses were also excluded where segmental data was unavailable. Applying these principles, the note records exclusion of several software development and IT-enabled services comparables, including entities with brand advantages, product development activity, extraordinary events, or unreliable segmental results, leading to a reduced transfer pricing adjustment for the assessee. Case-Laws Income Tax Thu, 12 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=192622