https://www.taxtmi.com/caselaws?id=377845 In transfer pricing benchmarking of a captive software development service provider, companies with materially different functions, product revenues, brand-driven advantages, inadequate segmental data, or failure of the related party transactions filter were treated as unsuitable comparables. Sonata Software Ltd. was excluded for failing the related party transactions filter, while E Infochips Bangalore Ltd., Infinite Data Systems Pvt. Ltd. and Infosys Ltd. were excluded because their revenue mix, service profile, scale, brand value, or lack of reliable segmental data made comparison unreliable. Working capital differences were also required to be adjusted to ensure proper arm's length benchmarking, resulting in partial relief to the assessee. en-us Tue, 02 Apr 2019 00:00:00 +0530 Wed, 03 Apr 2019 17:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=377845 In transfer pricing benchmarking of a captive software development service provider, companies with materially different functions, product revenues, brand-driven advantages, inadequate segmental data, or failure of the related party transactions filter were treated as unsuitable comparables. Sonata Software Ltd. was excluded for failing the related party transactions filter, while E Infochips Bangalore Ltd., Infinite Data Systems Pvt. Ltd. and Infosys Ltd. were excluded because their revenue mix, service profile, scale, brand value, or lack of reliable segmental data made comparison unreliable. Working capital differences were also required to be adjusted to ensure proper arm's length benchmarking, resulting in partial relief to the assessee. Case-Laws Income Tax Tue, 02 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=377845