https://www.taxtmi.com/caselaws?id=409653 Under TNMM, comparability depends on close functional similarity and available segmental data. A service-oriented passenger and baggage handling provider was contrasted with a logistics and freight-based entity lacking segmental accounts and showing materially different asset intensity and business model; that entity was therefore not a valid comparable. A company deriving substantial revenue from warehousing, equipment hire and other non-service activities, without segmental accounts, was likewise treated as not functionally comparable. The transfer pricing computation also required a uniform operating treatment of fringe benefit tax for both the tested party and the comparables, so the profit level indicator had to be recomputed on a consistent basis. en-us Wed, 30 Jun 2021 00:00:00 +0530 Wed, 14 Jul 2021 06:26:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=409653 Under TNMM, comparability depends on close functional similarity and available segmental data. A service-oriented passenger and baggage handling provider was contrasted with a logistics and freight-based entity lacking segmental accounts and showing materially different asset intensity and business model; that entity was therefore not a valid comparable. A company deriving substantial revenue from warehousing, equipment hire and other non-service activities, without segmental accounts, was likewise treated as not functionally comparable. The transfer pricing computation also required a uniform operating treatment of fringe benefit tax for both the tested party and the comparables, so the profit level indicator had to be recomputed on a consistent basis. Case-Laws Income Tax Wed, 30 Jun 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=409653