https://www.taxtmi.com/caselaws?id=466680 ITAT Mumbai reiterated that transfer pricing comparability must be based on like-with-like analysis. In the ITeS segment, companies with functional dissimilarity, unreliable segmental data, abnormal scale, restructuring effects, or entrepreneurial/high-end service features were excluded. In the software development segment, product-oriented entities, intangibles-heavy businesses, and research-intensive companies were found not comparable to a captive service provider and were excluded. The depreciation claim relating to earlier-year additions to the block of assets required factual verification of written down value and was remanded for examination according to law. en-us Mon, 13 Oct 2025 00:00:00 +0530 Mon, 16 Feb 2026 12:08:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466680 ITAT Mumbai reiterated that transfer pricing comparability must be based on like-with-like analysis. In the ITeS segment, companies with functional dissimilarity, unreliable segmental data, abnormal scale, restructuring effects, or entrepreneurial/high-end service features were excluded. In the software development segment, product-oriented entities, intangibles-heavy businesses, and research-intensive companies were found not comparable to a captive service provider and were excluded. The depreciation claim relating to earlier-year additions to the block of assets required factual verification of written down value and was remanded for examination according to law. Case-Laws Income Tax Mon, 13 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466680