https://www.taxtmi.com/caselaws?id=465393 Whether certain companies were valid comparables for benchmarking software development services was determined on functional comparability and extraordinary events. Where restructuring/segment changes in a comparable could affect its functional profile and the appellate authority had not examined the assessee's objections, the matter was remanded to the AO/TPO to re-evaluate after examining annual reports and record, and to implement the direction to test inclusion of one comparable under the applied filters and to verify alleged margin computation error for another. Companies with extraordinary events (overseas acquisition/expansion), lack of segmental data, software product orientation, diversified niche activities, abnormally high turnover, or restructuring were excluded/confirmed excluded, while a functionally similar company was upheld as comparable. On notional interest on receivables, deletion was upheld as the taxpayer did not charge interest to any party and was debt-free; Revenue's ground was dismissed. en-us Thu, 06 Apr 2023 00:00:00 +0530 Fri, 19 Dec 2025 21:18:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465393 Whether certain companies were valid comparables for benchmarking software development services was determined on functional comparability and extraordinary events. Where restructuring/segment changes in a comparable could affect its functional profile and the appellate authority had not examined the assessee's objections, the matter was remanded to the AO/TPO to re-evaluate after examining annual reports and record, and to implement the direction to test inclusion of one comparable under the applied filters and to verify alleged margin computation error for another. Companies with extraordinary events (overseas acquisition/expansion), lack of segmental data, software product orientation, diversified niche activities, abnormally high turnover, or restructuring were excluded/confirmed excluded, while a functionally similar company was upheld as comparable. On notional interest on receivables, deletion was upheld as the taxpayer did not charge interest to any party and was debt-free; Revenue's ground was dismissed. Case-Laws Income Tax Thu, 06 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465393