https://www.taxtmi.com/caselaws?id=775660 The ITAT Bangalore upheld the CIT(A)'s exclusion of several companies from the comparable set for transfer pricing adjustment due to functional dissimilarities with the assessee, an ITeS company. Companies engaged in high-end KPO services, software development, or having significantly different business models and turnover were excluded. The Tribunal agreed that entities providing engineering design, SaaS-based EMR software, or possessing high brand value and market leadership could not be comparables. Additionally, companies failing export earning or turnover filters or showing wide margin fluctuations were rightly excluded. Consequently, the appeal filed by the revenue was dismissed, affirming the CIT(A)'s decision to reject these companies as comparables for determining the arm's length price. en-us Tue, 03 Jun 2025 00:00:00 +0530 Tue, 29 Jul 2025 08:30:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775660 The ITAT Bangalore upheld the CIT(A)'s exclusion of several companies from the comparable set for transfer pricing adjustment due to functional dissimilarities with the assessee, an ITeS company. Companies engaged in high-end KPO services, software development, or having significantly different business models and turnover were excluded. The Tribunal agreed that entities providing engineering design, SaaS-based EMR software, or possessing high brand value and market leadership could not be comparables. Additionally, companies failing export earning or turnover filters or showing wide margin fluctuations were rightly excluded. Consequently, the appeal filed by the revenue was dismissed, affirming the CIT(A)'s decision to reject these companies as comparables for determining the arm's length price. Case-Laws Income Tax Tue, 03 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775660