https://www.taxtmi.com/caselaws?id=283736 Transfer pricing comparability requires selection of functionally similar companies that consistently satisfy accepted filters. Companies engaged in KPO or product-development activities, possessing substantial intangibles or brand value, lacking reliable segmental data, or showing abnormal results, distorted financials, or inconsistent employee-cost and related-party transaction profiles are unsuitable comparables. Entity-level margins cannot replace relevant segmental margins. For deductions under sections 10A and 10B, expenses excluded from export turnover, including travel and telecommunication expenses, must also be excluded from total turnover to preserve parity in the statutory formula and prevent distortion. Onsite work relief was not pursued. en-us Fri, 19 May 2017 00:00:00 +0530 Thu, 10 Oct 2019 11:38:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=283736 Transfer pricing comparability requires selection of functionally similar companies that consistently satisfy accepted filters. Companies engaged in KPO or product-development activities, possessing substantial intangibles or brand value, lacking reliable segmental data, or showing abnormal results, distorted financials, or inconsistent employee-cost and related-party transaction profiles are unsuitable comparables. Entity-level margins cannot replace relevant segmental margins. For deductions under sections 10A and 10B, expenses excluded from export turnover, including travel and telecommunication expenses, must also be excluded from total turnover to preserve parity in the statutory formula and prevent distortion. Onsite work relief was not pursued. Case-Laws Income Tax Fri, 19 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=283736