https://www.taxtmi.com/caselaws?id=310973 In transfer pricing for a captive software development service provider, comparables with materially higher turnover were treated as unsuitable because turnover is a relevant filter in determining arm's length price. The Tribunal also excluded companies with functionally different activities, including product development, software products, research and development, knowledge process outsourcing, and diversified services, especially where no reliable segmental data was available. Since those entities were not functionally comparable to low-risk contract software development services, they were removed from the comparable set and the assessee's appeal succeeded in part. en-us Wed, 23 Jun 2021 00:00:00 +0530 Wed, 29 Nov 2023 20:13:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310973 In transfer pricing for a captive software development service provider, comparables with materially higher turnover were treated as unsuitable because turnover is a relevant filter in determining arm's length price. The Tribunal also excluded companies with functionally different activities, including product development, software products, research and development, knowledge process outsourcing, and diversified services, especially where no reliable segmental data was available. Since those entities were not functionally comparable to low-risk contract software development services, they were removed from the comparable set and the assessee's appeal succeeded in part. Case-Laws Income Tax Wed, 23 Jun 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310973