https://www.taxtmi.com/caselaws?id=311247 In transfer pricing analysis for a captive ITeS business, several proposed comparables were excluded because they were functionally dissimilar, including entities engaged in KPO services, outsourcing or sub-contracting models, or activities beyond routine ITeS functions. Exclusion was also supported where companies failed revenue or turnover filters, lacked reliable segmental data, or showed abnormal margin fluctuations indicating peculiar business circumstances. One entity serving mainly a large group client base was likewise treated as not comparable on functional parameters. The Tribunal accepted the DRP's directions to remove these entities and found no distinguishing feature in the Revenue's challenge. en-us Thu, 23 Dec 2021 00:00:00 +0530 Thu, 14 Dec 2023 20:04:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311247 In transfer pricing analysis for a captive ITeS business, several proposed comparables were excluded because they were functionally dissimilar, including entities engaged in KPO services, outsourcing or sub-contracting models, or activities beyond routine ITeS functions. Exclusion was also supported where companies failed revenue or turnover filters, lacked reliable segmental data, or showed abnormal margin fluctuations indicating peculiar business circumstances. One entity serving mainly a large group client base was likewise treated as not comparable on functional parameters. The Tribunal accepted the DRP's directions to remove these entities and found no distinguishing feature in the Revenue's challenge. Case-Laws Income Tax Thu, 23 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311247