https://www.taxtmi.com/caselaws?id=790246 A diversified enterprise engaged in content solutions, publishing solutions and platform-based operations, with in-house development, research and acquisitions and no reliable segmental data, was held not to be functionally comparable to an assessee providing content development and editing services on a limited-risk, cost-plus basis. On the functional and annual report record, the entities were found to follow materially different business models, so the comparable was excluded from transfer pricing benchmarking. Once excluded, the assessee's margin fell within the arm's length range and the proposed transfer pricing adjustment did not survive. en-us Fri, 17 Apr 2026 00:00:00 +0530 Wed, 22 Apr 2026 08:47:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790246 A diversified enterprise engaged in content solutions, publishing solutions and platform-based operations, with in-house development, research and acquisitions and no reliable segmental data, was held not to be functionally comparable to an assessee providing content development and editing services on a limited-risk, cost-plus basis. On the functional and annual report record, the entities were found to follow materially different business models, so the comparable was excluded from transfer pricing benchmarking. Once excluded, the assessee's margin fell within the arm's length range and the proposed transfer pricing adjustment did not survive. Case-Laws Income Tax Fri, 17 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790246