https://www.taxtmi.com/caselaws?id=468198 In software development transfer pricing under TNMM, comparability must reflect turnover band, functional similarity and reliable segmental data. Companies with turnover above Rs. 200 crores were excluded because size, brand value and market reach materially distort margin comparison for a small service provider. Rheal Software Pvt. Ltd. was included because it did not meet the persistent loss filter, having reported profit in one relevant year. Daffodil Software Pvt. Ltd. was excluded because it earned both product and service revenue and lacked reliable segmental information, making it functionally incomparable to a captive software development service provider. en-us Thu, 28 Nov 2024 00:00:00 +0530 Tue, 21 Apr 2026 18:59:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468198 In software development transfer pricing under TNMM, comparability must reflect turnover band, functional similarity and reliable segmental data. Companies with turnover above Rs. 200 crores were excluded because size, brand value and market reach materially distort margin comparison for a small service provider. Rheal Software Pvt. Ltd. was included because it did not meet the persistent loss filter, having reported profit in one relevant year. Daffodil Software Pvt. Ltd. was excluded because it earned both product and service revenue and lacked reliable segmental information, making it functionally incomparable to a captive software development service provider. Case-Laws Income Tax Thu, 28 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468198