https://www.taxtmi.com/caselaws?id=311880 Transfer pricing comparability requires meaningful functional similarity, reliable revenue profile data and clear segmental information. Axis Integrated System Limited was excluded because its liaison and consultancy-style regulatory services were functionally different from marketing support services, while Killick Agencies and Marketing Limited was excluded because it acted as a foreign principal agent, earned commission and service income without segmental bifurcation, and had significant royalty expenditure. Spectrum Business Solutions Limited was also excluded because its internet marketing and admin support model, including virtual assistant and research services, was not sufficiently comparable to the assessee's market intelligence and sales support functions. The comparables set was therefore adjusted by exclusion of the disputed companies. en-us Fri, 04 Aug 2023 00:00:00 +0530 Thu, 18 Jan 2024 18:18:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311880 Transfer pricing comparability requires meaningful functional similarity, reliable revenue profile data and clear segmental information. Axis Integrated System Limited was excluded because its liaison and consultancy-style regulatory services were functionally different from marketing support services, while Killick Agencies and Marketing Limited was excluded because it acted as a foreign principal agent, earned commission and service income without segmental bifurcation, and had significant royalty expenditure. Spectrum Business Solutions Limited was also excluded because its internet marketing and admin support model, including virtual assistant and research services, was not sufficiently comparable to the assessee's market intelligence and sales support functions. The comparables set was therefore adjusted by exclusion of the disputed companies. Case-Laws Income Tax Fri, 04 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311880