https://www.taxtmi.com/caselaws?id=380466 Functional comparability under the transfer pricing regime was decisive for an assessee engaged in software development services. Cybermate Infotek Ltd. and Cybercom Datamatics Information Solutions Ltd. were excluded because they had mixed software product and service activities without separate segmental data. Infobeans Systems Pvt. Ltd. was also excluded due to mixed activities, lack of segmental details, and an extraordinary demerger event. Thirdware Solutions Ltd. was rejected as a comparable because it derived revenue from licences, subscriptions and software services, owned intangibles, and lacked segmental clarity. E-Zest Solutions Ltd. was excluded because it carried on KPO services, which were not comparable to software development services. The transfer pricing adjustment therefore did not survive. en-us Fri, 17 May 2019 00:00:00 +0530 Tue, 21 May 2019 10:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=380466 Functional comparability under the transfer pricing regime was decisive for an assessee engaged in software development services. Cybermate Infotek Ltd. and Cybercom Datamatics Information Solutions Ltd. were excluded because they had mixed software product and service activities without separate segmental data. Infobeans Systems Pvt. Ltd. was also excluded due to mixed activities, lack of segmental details, and an extraordinary demerger event. Thirdware Solutions Ltd. was rejected as a comparable because it derived revenue from licences, subscriptions and software services, owned intangibles, and lacked segmental clarity. E-Zest Solutions Ltd. was excluded because it carried on KPO services, which were not comparable to software development services. The transfer pricing adjustment therefore did not survive. Case-Laws Income Tax Fri, 17 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=380466