https://www.taxtmi.com/caselaws?id=442191 Transfer pricing review focuses on comparable selection and FAR analysis for a captive service provider operating on a cost plus markup. Functional dissimilarity of proposed comparables due to ownership of intangibles, independent R&D and brand value leads to their exclusion. Two comparables are remitted to the assessing officer/TPO for verification of export revenue and FAR conformity and possible inclusion if they meet filters. Margins of specified comparables are to be recomputed by the assessing officer/TPO in accordance with law. Bad and doubtful debts and related provisions are to be treated as operating items when computing comparable operating margins. en-us Fri, 16 Jun 2023 00:00:00 +0530 Wed, 28 Jan 2026 16:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442191 Transfer pricing review focuses on comparable selection and FAR analysis for a captive service provider operating on a cost plus markup. Functional dissimilarity of proposed comparables due to ownership of intangibles, independent R&D and brand value leads to their exclusion. Two comparables are remitted to the assessing officer/TPO for verification of export revenue and FAR conformity and possible inclusion if they meet filters. Margins of specified comparables are to be recomputed by the assessing officer/TPO in accordance with law. Bad and doubtful debts and related provisions are to be treated as operating items when computing comparable operating margins. Case-Laws Income Tax Fri, 16 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442191