https://www.taxtmi.com/caselaws?id=462246 Transfer pricing comparability must be tested on functional similarity and, where a company has multiple lines of business, reliable segmental results are necessary to isolate the relevant activity. Venus Diagnostics Ltd. was excluded because it operated as a diagnostic centre rather than rendering research services, making it functionally different from the assessee's contract research services. Syngene International Limited was also excluded because it carried on contract research as well as sale of compounds, and no segmental details were available to separate the research margin from the other business. The exclusion of both companies from the comparable set was therefore justified, and the Revenue's challenge failed. en-us Fri, 13 Apr 2018 00:00:00 +0530 Wed, 04 Jun 2025 13:15:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462246 Transfer pricing comparability must be tested on functional similarity and, where a company has multiple lines of business, reliable segmental results are necessary to isolate the relevant activity. Venus Diagnostics Ltd. was excluded because it operated as a diagnostic centre rather than rendering research services, making it functionally different from the assessee's contract research services. Syngene International Limited was also excluded because it carried on contract research as well as sale of compounds, and no segmental details were available to separate the research margin from the other business. The exclusion of both companies from the comparable set was therefore justified, and the Revenue's challenge failed. Case-Laws Income Tax Fri, 13 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462246