https://www.taxtmi.com/caselaws?id=434696 Functional comparability in ITES transfer pricing must be tested against segmental revenue and business profile, so entities deriving income from accounting, healthcare, e-publishing or other non-ITES activities, or undergoing material structural change, are not suitable comparables. Where a proposed comparable lacks demonstrated ITES revenue, exclusion is justified; where BPO comparability or negative working capital adjustment depends on factual verification, fresh examination is required. The article also notes that employee's contribution to PF and ESI deposited beyond the statutory due date remains disallowable under section 36(1)(va) on binding precedent. en-us Thu, 05 Jan 2023 00:00:00 +0530 Wed, 01 Mar 2023 10:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434696 Functional comparability in ITES transfer pricing must be tested against segmental revenue and business profile, so entities deriving income from accounting, healthcare, e-publishing or other non-ITES activities, or undergoing material structural change, are not suitable comparables. Where a proposed comparable lacks demonstrated ITES revenue, exclusion is justified; where BPO comparability or negative working capital adjustment depends on factual verification, fresh examination is required. The article also notes that employee's contribution to PF and ESI deposited beyond the statutory due date remains disallowable under section 36(1)(va) on binding precedent. Case-Laws Income Tax Thu, 05 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434696