https://www.taxtmi.com/caselaws?id=282063 Transfer pricing comparables under Chapter X must be tested on a proper FAR analysis, with TNMM applied on a sound factual basis. In the marketing support and customer support segment, disputed comparables were sent back for fresh adjudication because the assessee had not placed enough material to show they were functionally dissimilar. In the software research and development segment, the inclusion and exclusion of comparables, including issues of turnover, related party transactions, and segmental data, also required fresh examination. The matter was therefore restored to the AO/TPO for reconsideration of comparability and verification of the relevant filters. en-us Wed, 14 Sep 2016 00:00:00 +0530 Sat, 20 Jul 2019 07:19:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=282063 Transfer pricing comparables under Chapter X must be tested on a proper FAR analysis, with TNMM applied on a sound factual basis. In the marketing support and customer support segment, disputed comparables were sent back for fresh adjudication because the assessee had not placed enough material to show they were functionally dissimilar. In the software research and development segment, the inclusion and exclusion of comparables, including issues of turnover, related party transactions, and segmental data, also required fresh examination. The matter was therefore restored to the AO/TPO for reconsideration of comparability and verification of the relevant filters. Case-Laws Income Tax Wed, 14 Sep 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=282063