https://www.taxtmi.com/caselaws?id=365729 Functional comparability in transfer pricing must be assessed with close attention to the service profile, risk allocation, scale, intangibles and segmental data. Companies engaged in broader engineering, procurement, consultancy, project management, trading or government-linked work were treated as unsuitable comparables for a captive engineering design provider, and high-end, brand-driven, diversified or software-oriented entities were also excluded from support-service segments. The captive service provider character of the assessee supported risk adjustment to neutralise lower business risk against independent comparables. A receivables adjustment was also deleted because no separate transfer pricing addition was justified on the facts, including the absence of a borrowing-cost nexus. The transfer pricing additions therefore did not survive. en-us Mon, 20 Aug 2018 00:00:00 +0530 Wed, 22 Aug 2018 08:06:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=365729 Functional comparability in transfer pricing must be assessed with close attention to the service profile, risk allocation, scale, intangibles and segmental data. Companies engaged in broader engineering, procurement, consultancy, project management, trading or government-linked work were treated as unsuitable comparables for a captive engineering design provider, and high-end, brand-driven, diversified or software-oriented entities were also excluded from support-service segments. The captive service provider character of the assessee supported risk adjustment to neutralise lower business risk against independent comparables. A receivables adjustment was also deleted because no separate transfer pricing addition was justified on the facts, including the absence of a borrowing-cost nexus. The transfer pricing additions therefore did not survive. Case-Laws Income Tax Mon, 20 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=365729