https://www.taxtmi.com/caselaws?id=432141 Transfer pricing adjustment guidance addresses comparable selection for an assessee providing software development services to its associated enterprise. Companies with turnover outside Rs.200 crore2000 crore were excluded as functionally dissimilar to the assessee, and a related-party transaction (RPT) filter is to be applied using a 15% threshold. The reasoning grounds comparable inclusion on functional similarity and turnover proximity, with the operative consequence that comparables failing these filters are to be disregarded, narrowing the comparable set for arm's length determination. en-us Tue, 20 Sep 2022 00:00:00 +0530 Wed, 28 Jan 2026 16:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432141 Transfer pricing adjustment guidance addresses comparable selection for an assessee providing software development services to its associated enterprise. Companies with turnover outside Rs.200 crore2000 crore were excluded as functionally dissimilar to the assessee, and a related-party transaction (RPT) filter is to be applied using a 15% threshold. The reasoning grounds comparable inclusion on functional similarity and turnover proximity, with the operative consequence that comparables failing these filters are to be disregarded, narrowing the comparable set for arm's length determination. Case-Laws Income Tax Tue, 20 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432141