https://www.taxtmi.com/caselaws?id=345795 In transfer pricing for marketing support services, comparables must be functionally similar to the tested party. Agrima Consultants International Ltd. was treated as a suitable comparable because it matched the service profile, while IDC India Ltd. was excluded for being engaged in knowledge process outsourcing and Empire Industries Ltd. was excluded for deriving income from manufacturing, trading and indenting activities. The comparable set was therefore to be reworked and the arm's length price recomputed. The transfer pricing adjustment would not survive if the revised mean operating margin placed the assessee within the permissible arm's length range. en-us Wed, 15 Mar 2017 00:00:00 +0530 Thu, 27 Jul 2017 08:14:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=345795 In transfer pricing for marketing support services, comparables must be functionally similar to the tested party. Agrima Consultants International Ltd. was treated as a suitable comparable because it matched the service profile, while IDC India Ltd. was excluded for being engaged in knowledge process outsourcing and Empire Industries Ltd. was excluded for deriving income from manufacturing, trading and indenting activities. The comparable set was therefore to be reworked and the arm's length price recomputed. The transfer pricing adjustment would not survive if the revised mean operating margin placed the assessee within the permissible arm's length range. Case-Laws Income Tax Wed, 15 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=345795