https://www.taxtmi.com/caselaws?id=393404 Transfer-pricing comparability analysis allowed exclusion of companies that were functionally different, lacked reliable segmental results, or were affected by brand advantage, intangibles, assured revenue models, restructuring, amalgamation, or other extraordinary events; the High Court upheld those exclusions and accepted the Tribunal's factual findings as not perverse. For the later assessment year, the matter was remanded because relevant additional evidence on the assessee's software development activity had not been adequately considered and both sides had not been given a proper opportunity, requiring fresh benchmarking and reconsideration of the software development versus ITES characterization. en-us Wed, 30 Oct 2019 00:00:00 +0530 Tue, 16 Dec 2025 17:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=393404 Transfer-pricing comparability analysis allowed exclusion of companies that were functionally different, lacked reliable segmental results, or were affected by brand advantage, intangibles, assured revenue models, restructuring, amalgamation, or other extraordinary events; the High Court upheld those exclusions and accepted the Tribunal's factual findings as not perverse. For the later assessment year, the matter was remanded because relevant additional evidence on the assessee's software development activity had not been adequately considered and both sides had not been given a proper opportunity, requiring fresh benchmarking and reconsideration of the software development versus ITES characterization. Case-Laws Income Tax Wed, 30 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=393404