https://www.taxtmi.com/caselaws?id=283736 Transfer pricing comparables must be functionally similar to the tested service provider and must satisfy consistently applied filters; companies engaged in KPO or product development, those with significant intangibles or brand value, those lacking reliable segmental data, and those with distorted financials were treated as unsuitable comparables. Where only a software segment was relevant, entity-level margins could not replace segmental results. For deduction under section 10A and section 10B, any expense excluded from export turnover must also be excluded from total turnover to preserve parity in the statutory formula. The note records that these principles favoured the assessee on comparability and turnover-computation issues. 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 comparables must be functionally similar to the tested service provider and must satisfy consistently applied filters; companies engaged in KPO or product development, those with significant intangibles or brand value, those lacking reliable segmental data, and those with distorted financials were treated as unsuitable comparables. Where only a software segment was relevant, entity-level margins could not replace segmental results. For deduction under section 10A and section 10B, any expense excluded from export turnover must also be excluded from total turnover to preserve parity in the statutory formula. The note records that these principles favoured the assessee on comparability and turnover-computation issues. Case-Laws Income Tax Fri, 19 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=283736