https://www.taxtmi.com/caselaws?id=406124 In transfer pricing analysis for a captive software development service provider, a comparable chosen in the assessee's study may still be excluded where it is not truly comparable, because there is no estoppel against law and arm's length price must rest on correct comparables. Functional dissimilarity, diversified operations, lack of reliable segmental data, software product revenue, and failure of filters justified exclusion of Acropetal Technologies Ltd., E-Infochips Ltd., ICRA Techno Analytics Ltd. and Persistent Systems & Solutions Ltd., while E-Zest Solutions Ltd. required fresh verification. Earlier remand approaches were followed for Akshay Software Technologies Ltd., LGS Global Ltd. and Thinksoft Global Services Ltd., and working capital adjustment was to be recomputed on actual basis to neutralise economic differences. en-us Thu, 25 Mar 2021 00:00:00 +0530 Wed, 07 Apr 2021 09:16:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406124 In transfer pricing analysis for a captive software development service provider, a comparable chosen in the assessee's study may still be excluded where it is not truly comparable, because there is no estoppel against law and arm's length price must rest on correct comparables. Functional dissimilarity, diversified operations, lack of reliable segmental data, software product revenue, and failure of filters justified exclusion of Acropetal Technologies Ltd., E-Infochips Ltd., ICRA Techno Analytics Ltd. and Persistent Systems & Solutions Ltd., while E-Zest Solutions Ltd. required fresh verification. Earlier remand approaches were followed for Akshay Software Technologies Ltd., LGS Global Ltd. and Thinksoft Global Services Ltd., and working capital adjustment was to be recomputed on actual basis to neutralise economic differences. Case-Laws Income Tax Thu, 25 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406124