https://www.taxtmi.com/caselaws?id=778257 ITAT held that several large conglomerate comparables must be excluded from the transfer-pricing comparability set because their substantially larger turnover and brand-related intangibles render them non-comparable to the tested party; the TPO/AO is directed to remove them. The tribunal upheld the inclusion of two software-services firms as functionally comparable despite profit volatility. It rejected the taxpayer's attempt to resurrect comparables from its rejected TP study, finding such inclusion would amount to cherry-picking. The tribunal remitted the working-capital adjustment issue to the TPO for fresh consideration with opportunity of hearing. en-us Wed, 10 Sep 2025 00:00:00 +0530 Fri, 12 Sep 2025 08:48:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778257 ITAT held that several large conglomerate comparables must be excluded from the transfer-pricing comparability set because their substantially larger turnover and brand-related intangibles render them non-comparable to the tested party; the TPO/AO is directed to remove them. The tribunal upheld the inclusion of two software-services firms as functionally comparable despite profit volatility. It rejected the taxpayer's attempt to resurrect comparables from its rejected TP study, finding such inclusion would amount to cherry-picking. The tribunal remitted the working-capital adjustment issue to the TPO for fresh consideration with opportunity of hearing. Case-Laws Income Tax Wed, 10 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778257