https://www.taxtmi.com/caselaws?id=275227 Transfer pricing comparability must rest on a strict FAR analysis: entities with functional dissimilarity, KPO features, significant intangibles, brand-driven advantages, abnormal scale, or unreliable segmental data are not suitable comparables, and year-end comparables require reliable period-specific data before inclusion or exclusion. The impugned comparables were therefore directed to be re-examined and the arm's length computation recomputed accordingly. Grounds relating to interest charging and penalty initiation were premature and did not call for substantive adjudication, so no relief was granted on those issues. en-us Wed, 28 Mar 2018 00:00:00 +0530 Mon, 24 Sep 2018 07:33:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=275227 Transfer pricing comparability must rest on a strict FAR analysis: entities with functional dissimilarity, KPO features, significant intangibles, brand-driven advantages, abnormal scale, or unreliable segmental data are not suitable comparables, and year-end comparables require reliable period-specific data before inclusion or exclusion. The impugned comparables were therefore directed to be re-examined and the arm's length computation recomputed accordingly. Grounds relating to interest charging and penalty initiation were premature and did not call for substantive adjudication, so no relief was granted on those issues. Case-Laws Income Tax Wed, 28 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=275227