https://www.taxtmi.com/caselaws?id=192622 TNMM benchmarking requires functional comparability; satisfaction of quantitative filters alone does not establish that a company is a suitable comparable. Companies may be excluded where their business model, brand ownership, proprietary products, research and marketing intensity, scale, risk profile, or extraordinary events materially affect profitability. Mixed product-and-service companies without reliable segmental data may also fail the comparability test. Software development and IT-enabled service comparables were excluded where they had significant brand-related advantages, product-development activities, high-end or functionally divergent services, acquisition or restructuring effects, or materially different entrepreneurial risks. Excluding those entities reduced the transfer-pricing adjustment. 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 TNMM benchmarking requires functional comparability; satisfaction of quantitative filters alone does not establish that a company is a suitable comparable. Companies may be excluded where their business model, brand ownership, proprietary products, research and marketing intensity, scale, risk profile, or extraordinary events materially affect profitability. Mixed product-and-service companies without reliable segmental data may also fail the comparability test. Software development and IT-enabled service comparables were excluded where they had significant brand-related advantages, product-development activities, high-end or functionally divergent services, acquisition or restructuring effects, or materially different entrepreneurial risks. Excluding those entities reduced the transfer-pricing adjustment. Case-Laws Income Tax Thu, 12 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=192622