https://www.taxtmi.com/caselaws?id=345544 For transfer pricing purposes, market research services are not functionally comparable to information technology enabled services because their activities, processes and value drivers differ materially; mere use of computers or data processing does not convert market research into ITES, so ITES comparables are inappropriate for benchmarking. Where the assessee is not comparable to the tested set, the transfer pricing adjustment based on those comparables cannot be sustained and arm's length price must be examined on a consistent basis. The notional interest addition on work-in-progress was deleted in line with the assessee's earlier years, while the section 80G claim was restored for verification against the donation evidence and consequential relief. en-us Wed, 09 Nov 2016 00:00:00 +0530 Thu, 20 Jul 2017 07:37:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=345544 For transfer pricing purposes, market research services are not functionally comparable to information technology enabled services because their activities, processes and value drivers differ materially; mere use of computers or data processing does not convert market research into ITES, so ITES comparables are inappropriate for benchmarking. Where the assessee is not comparable to the tested set, the transfer pricing adjustment based on those comparables cannot be sustained and arm's length price must be examined on a consistent basis. The notional interest addition on work-in-progress was deleted in line with the assessee's earlier years, while the section 80G claim was restored for verification against the donation evidence and consequential relief. Case-Laws Income Tax Wed, 09 Nov 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=345544