https://www.taxtmi.com/caselaws?id=392486 In transfer pricing comparability, an otherwise functionally similar company cannot be excluded merely because it follows a different accounting year end, so Caliber Point Business Solutions Limited was retained as a comparable. A company with a materially different business model and functions, such as one engaged in publishing solutions, digitization and content creation, is not comparable to a captive low-end ITeS provider, so MPS Limited was excluded. The transfer pricing adjustment was to be recomputed accordingly, with the remaining grounds treated as not pressed. en-us Wed, 05 Feb 2020 00:00:00 +0530 Fri, 21 Feb 2020 12:39:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=392486 In transfer pricing comparability, an otherwise functionally similar company cannot be excluded merely because it follows a different accounting year end, so Caliber Point Business Solutions Limited was retained as a comparable. A company with a materially different business model and functions, such as one engaged in publishing solutions, digitization and content creation, is not comparable to a captive low-end ITeS provider, so MPS Limited was excluded. The transfer pricing adjustment was to be recomputed accordingly, with the remaining grounds treated as not pressed. Case-Laws Income Tax Wed, 05 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=392486