https://www.taxtmi.com/caselaws?id=790474 Functionally dissimilar comparables must be excluded in transfer pricing benchmarking, so back-office support services could include Keystone Integrated Marketing Services while Buzzworks Business Services and Crayon Advertising were rejected for dissimilar functions. Bought-in third-party costs in the contract R&D segment were treated as pass-through items without value addition and excluded from the PLI base, and working capital adjustment was allowed to reflect comparability differences. Binding Dispute Resolution Panel directions required royalty attribution to be recomputed after set-off of contract R&D income. The income adopted for tax computation also had to be verified for an apparent arithmetical error, and foreign tax credit was to be examined and granted in accordance with law. en-us Wed, 22 Apr 2026 00:00:00 +0530 Sat, 25 Apr 2026 08:51:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790474 Functionally dissimilar comparables must be excluded in transfer pricing benchmarking, so back-office support services could include Keystone Integrated Marketing Services while Buzzworks Business Services and Crayon Advertising were rejected for dissimilar functions. Bought-in third-party costs in the contract R&D segment were treated as pass-through items without value addition and excluded from the PLI base, and working capital adjustment was allowed to reflect comparability differences. Binding Dispute Resolution Panel directions required royalty attribution to be recomputed after set-off of contract R&D income. The income adopted for tax computation also had to be verified for an apparent arithmetical error, and foreign tax credit was to be examined and granted in accordance with law. Case-Laws Income Tax Wed, 22 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790474