https://www.taxtmi.com/caselaws?id=300601 ITAT Hyderabad held that comparability in transfer pricing must rest on functional similarity and the presence of extraordinary events. MindTree Ltd. was rightly excluded because it underwent strategic acquisition, amalgamation and subsidiary dissolution, and also had heavy R&D and significant intangibles, making it functionally dissimilar. E-Infochips Bangalore Ltd., Kals Information Systems Ltd. and Persistent Systems Ltd. were also excluded because prior co-ordinate bench decisions found them not comparable to routine software development, with Persistent Systems treated as engaged in outsourced product development. The arm's length adjustment on interest for delayed receivables was deleted because it was made without comparable uncontrolled data for the relevant segment. en-us Mon, 15 Mar 2021 00:00:00 +0530 Tue, 15 Feb 2022 06:56:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=300601 ITAT Hyderabad held that comparability in transfer pricing must rest on functional similarity and the presence of extraordinary events. MindTree Ltd. was rightly excluded because it underwent strategic acquisition, amalgamation and subsidiary dissolution, and also had heavy R&D and significant intangibles, making it functionally dissimilar. E-Infochips Bangalore Ltd., Kals Information Systems Ltd. and Persistent Systems Ltd. were also excluded because prior co-ordinate bench decisions found them not comparable to routine software development, with Persistent Systems treated as engaged in outsourced product development. The arm's length adjustment on interest for delayed receivables was deleted because it was made without comparable uncontrolled data for the relevant segment. Case-Laws Income Tax Mon, 15 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=300601