https://www.taxtmi.com/caselaws?id=397863 Transfer pricing comparability requires functional similarity and reliable period alignment: Alphageo (seismic data services) and TCG Lifesciences (contract research) were functionally different from technical support services, and Pfizer's November year-end data was not comparable with a March year-end basis, so the corresponding adjustment was deleted. Back-office support services were treated as requiring the same fresh adjudication already ordered in the assessee's earlier year, so that matter was restored to the Assessing Officer/TPO. For withholding tax, global support service fees paid to a Singapore entity were not fees for technical services because the services did not satisfy the "make available" test, so the section 40(a)(i) disallowance was deleted. en-us Mon, 27 Jul 2020 00:00:00 +0530 Mon, 31 Aug 2020 18:24:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=397863 Transfer pricing comparability requires functional similarity and reliable period alignment: Alphageo (seismic data services) and TCG Lifesciences (contract research) were functionally different from technical support services, and Pfizer's November year-end data was not comparable with a March year-end basis, so the corresponding adjustment was deleted. Back-office support services were treated as requiring the same fresh adjudication already ordered in the assessee's earlier year, so that matter was restored to the Assessing Officer/TPO. For withholding tax, global support service fees paid to a Singapore entity were not fees for technical services because the services did not satisfy the "make available" test, so the section 40(a)(i) disallowance was deleted. Case-Laws Income Tax Mon, 27 Jul 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=397863