https://www.taxtmi.com/caselaws?id=193408 Transfer pricing comparability turns on functional similarity, not profit or loss alone. A routine, low-risk service provider's market support functions were held comparable with Capital Trusts Ltd. and Agrima Consultants International Ltd. because their relevant consultancy and feasibility-report activities were functionally similar, while loss-making status did not by itself justify exclusion. IDC (India) Ltd. was treated as a high-end KPO provider and excluded, and Empire Industries Ltd. was excluded because its principal income came from manufacturing, trading and indenting rather than support services. The set-off claim for brought forward losses and unabsorbed depreciation was not finally decided and was remitted for verification in line with prior directions. en-us Fri, 26 Aug 2016 00:00:00 +0530 Fri, 28 Jul 2017 08:30:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=193408 Transfer pricing comparability turns on functional similarity, not profit or loss alone. A routine, low-risk service provider's market support functions were held comparable with Capital Trusts Ltd. and Agrima Consultants International Ltd. because their relevant consultancy and feasibility-report activities were functionally similar, while loss-making status did not by itself justify exclusion. IDC (India) Ltd. was treated as a high-end KPO provider and excluded, and Empire Industries Ltd. was excluded because its principal income came from manufacturing, trading and indenting rather than support services. The set-off claim for brought forward losses and unabsorbed depreciation was not finally decided and was remitted for verification in line with prior directions. Case-Laws Income Tax Fri, 26 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=193408