https://www.taxtmi.com/caselaws?id=439852 A captive software development service provider was compared under transfer pricing principles by testing functional similarity, segmental reliability, onsite operations, brand value, intangibles, R&D intensity and related party transactions. Mind Tree, L&T Infotech, Infobeans, Persistent Systems and Infosys were excluded because their profiles were materially different or comparability data was unreliable. I2T2 India and Infomile Technologies were directed to be included because non-disclosure of related party transaction details alone was not enough to reject otherwise functionally comparable companies. Working capital adjustment was accepted in principle and remanded for fresh computation on actual basis. en-us Thu, 25 May 2023 00:00:00 +0530 Mon, 04 May 2026 17:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439852 A captive software development service provider was compared under transfer pricing principles by testing functional similarity, segmental reliability, onsite operations, brand value, intangibles, R&D intensity and related party transactions. Mind Tree, L&T Infotech, Infobeans, Persistent Systems and Infosys were excluded because their profiles were materially different or comparability data was unreliable. I2T2 India and Infomile Technologies were directed to be included because non-disclosure of related party transaction details alone was not enough to reject otherwise functionally comparable companies. Working capital adjustment was accepted in principle and remanded for fresh computation on actual basis. Case-Laws Income Tax Thu, 25 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439852