https://www.taxtmi.com/caselaws?id=434696 Functional comparability in ITES benchmarking depends on the assessee's segment and revenue profile. Six entities were excluded because they were outside the ITES segment or performed accounting, healthcare or e-publishing functions, with one also affected by a merger. Proposed comparables lacking ITES revenue were rejected, while the comparability of a BPO entity required fresh examination. Negative working capital adjustment required verification of whether working capital risk was assumed. Employee PF and ESI contributions paid after the statutory due date remained disallowable under section 36(1)(va). Transfer pricing relief was granted only for exclusion of unsuitable comparables; specified issues were remanded for fresh consideration. 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 benchmarking depends on the assessee's segment and revenue profile. Six entities were excluded because they were outside the ITES segment or performed accounting, healthcare or e-publishing functions, with one also affected by a merger. Proposed comparables lacking ITES revenue were rejected, while the comparability of a BPO entity required fresh examination. Negative working capital adjustment required verification of whether working capital risk was assumed. Employee PF and ESI contributions paid after the statutory due date remained disallowable under section 36(1)(va). Transfer pricing relief was granted only for exclusion of unsuitable comparables; specified issues were remanded for fresh consideration. Case-Laws Income Tax Thu, 05 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434696