https://www.taxtmi.com/caselaws?id=788801 Transfer pricing comparability requires functional similarity, comparable risk profile, and reliable segmental data. HSCC India Limited was excluded because it was a Government of India enterprise with government-linked project access and support, making its consultancy and project services materially different from the assessee's technical support and payroll administration services. Mitcon Consultancy and Engineering Services Limited was also excluded because it carried on diversified activities and its signed financial statements did not provide dependable segment-wise data to isolate the relevant consultancy function. The text states that both companies were unsuitable comparables and that the assessee succeeded in challenging their inclusion. en-us Wed, 25 Mar 2026 00:00:00 +0530 Sat, 28 Mar 2026 08:57:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788801 Transfer pricing comparability requires functional similarity, comparable risk profile, and reliable segmental data. HSCC India Limited was excluded because it was a Government of India enterprise with government-linked project access and support, making its consultancy and project services materially different from the assessee's technical support and payroll administration services. Mitcon Consultancy and Engineering Services Limited was also excluded because it carried on diversified activities and its signed financial statements did not provide dependable segment-wise data to isolate the relevant consultancy function. The text states that both companies were unsuitable comparables and that the assessee succeeded in challenging their inclusion. Case-Laws Income Tax Wed, 25 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788801