https://www.taxtmi.com/caselaws?id=306278 Transfer pricing comparability must rest on functional and economic similarity, including service profile and turnover. Accentia Technologies Ltd. was held includible because the record showed medical transcription, billing, collection and coding services, not product sales. Acropetal Technologies Ltd., Eclerx Services Ltd., Infosys BPO Ltd. and TCS E-Serve Ltd. were treated as unsuitable comparables because of functional dissimilarity or their status as mega entities with much higher turnover. A working capital adjustment was sustained where the accounts showed substantial receivables and consequent fund blockage, indicating that the assessee did bear working capital risk. en-us Thu, 19 Nov 2020 00:00:00 +0530 Fri, 20 Jan 2023 07:16:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306278 Transfer pricing comparability must rest on functional and economic similarity, including service profile and turnover. Accentia Technologies Ltd. was held includible because the record showed medical transcription, billing, collection and coding services, not product sales. Acropetal Technologies Ltd., Eclerx Services Ltd., Infosys BPO Ltd. and TCS E-Serve Ltd. were treated as unsuitable comparables because of functional dissimilarity or their status as mega entities with much higher turnover. A working capital adjustment was sustained where the accounts showed substantial receivables and consequent fund blockage, indicating that the assessee did bear working capital risk. Case-Laws Income Tax Thu, 19 Nov 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306278