https://www.taxtmi.com/caselaws?id=436051 Transfer pricing comparability should reflect functional similarity, turnover size and economic reality. High-turnover software companies may be excluded where the tested entity is a much smaller captive service provider, while entities with multiple service lines and no reliable segmental data may fail functional comparability. Working capital differences materially affect profitability and may justify adjustment. A loan balance that is only a book entry, or otherwise reflected as nil in the accounts, does not justify imputing notional interest for the relevant year. Certain comparable-selection and operating-item issues may be remitted for fresh verification, and any section 234A levy must be tested for applicability before being sustained. en-us Wed, 21 Dec 2022 00:00:00 +0530 Mon, 03 Apr 2023 10:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436051 Transfer pricing comparability should reflect functional similarity, turnover size and economic reality. High-turnover software companies may be excluded where the tested entity is a much smaller captive service provider, while entities with multiple service lines and no reliable segmental data may fail functional comparability. Working capital differences materially affect profitability and may justify adjustment. A loan balance that is only a book entry, or otherwise reflected as nil in the accounts, does not justify imputing notional interest for the relevant year. Certain comparable-selection and operating-item issues may be remitted for fresh verification, and any section 234A levy must be tested for applicability before being sustained. Case-Laws Income Tax Wed, 21 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436051