https://www.taxtmi.com/caselaws?id=195557 In ITES transfer pricing benchmarking under TNMM, Accentia Technologies Ltd. was excluded because extraordinary events such as acquisition and amalgamation distorted comparability. Cosmic Global Ltd. and Informed Technologies India Ltd. were also rejected as comparables due to their outsourced business model, lower employee-cost intensity and functional dissimilarity with a captive ITES provider. Jeevan Softech Ltd.'s margin required correction because segmental ITES revenue had not been properly considered. With the comparables revised, the transfer pricing adjustment had to be recomputed, the challenge to single-year data failed for want of a legal basis, and the connected interest, penalty and risk-adjustment grounds did not survive. en-us Tue, 31 May 2016 00:00:00 +0530 Fri, 03 Nov 2017 17:36:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=195557 In ITES transfer pricing benchmarking under TNMM, Accentia Technologies Ltd. was excluded because extraordinary events such as acquisition and amalgamation distorted comparability. Cosmic Global Ltd. and Informed Technologies India Ltd. were also rejected as comparables due to their outsourced business model, lower employee-cost intensity and functional dissimilarity with a captive ITES provider. Jeevan Softech Ltd.'s margin required correction because segmental ITES revenue had not been properly considered. With the comparables revised, the transfer pricing adjustment had to be recomputed, the challenge to single-year data failed for want of a legal basis, and the connected interest, penalty and risk-adjustment grounds did not survive. Case-Laws Income Tax Tue, 31 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=195557