https://www.taxtmi.com/caselaws?id=376123 For transfer pricing purposes, a company with materially different revenue streams, diversified operations, or significant brand-driven advantages cannot be treated as a valid comparable for a captive service provider with limited functions. Kerala Travels Interserve Ltd. was excluded because its income came substantially from airlines commission and ancillary activities rather than tour operations, making its business profile materially different. Cox & Kings Ltd. was also excluded because its multi-segment operations and brand strength distorted comparability with the assessee's tourism service profile. The arm's length price was therefore required to be recomputed after removing both comparables. en-us Fri, 08 Jun 2018 00:00:00 +0530 Sat, 02 Mar 2019 10:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=376123 For transfer pricing purposes, a company with materially different revenue streams, diversified operations, or significant brand-driven advantages cannot be treated as a valid comparable for a captive service provider with limited functions. Kerala Travels Interserve Ltd. was excluded because its income came substantially from airlines commission and ancillary activities rather than tour operations, making its business profile materially different. Cox & Kings Ltd. was also excluded because its multi-segment operations and brand strength distorted comparability with the assessee's tourism service profile. The arm's length price was therefore required to be recomputed after removing both comparables. Case-Laws Income Tax Fri, 08 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=376123