https://www.taxtmi.com/caselaws?id=273985 Comparable companies in transfer pricing may be excluded where they are functionally dissimilar to the tested IT-enabled services provider or where reliable segmental data is unavailable. The Tribunal also treated high brand value and an upscale business profile as relevant comparability factors for some entities, and the HC found these considerations consistent with the governing approach and supported by precedent. On the factual record, especially the finding of functional dissimilarity, the exclusion of the disputed comparables was upheld and the Revenue's challenge failed. en-us Mon, 26 Feb 2018 00:00:00 +0530 Sun, 22 Jul 2018 16:07:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=273985 Comparable companies in transfer pricing may be excluded where they are functionally dissimilar to the tested IT-enabled services provider or where reliable segmental data is unavailable. The Tribunal also treated high brand value and an upscale business profile as relevant comparability factors for some entities, and the HC found these considerations consistent with the governing approach and supported by precedent. On the factual record, especially the finding of functional dissimilarity, the exclusion of the disputed comparables was upheld and the Revenue's challenge failed. Case-Laws Income Tax Mon, 26 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=273985