https://www.taxtmi.com/caselaws?id=468323 A transfer pricing comparable must be functionally similar to the tested party under TNMM, including similarity in risk profile, asset base and operating model. Acropetal Technologies Ltd. was excluded because its low employee cost, outsourced and onsite development, R&D activity and acquisition-driven growth made it functionally different from the assessee's business support services. e4e Healthcare Business Services Pvt. Ltd. was included because its healthcare outsourcing and support services were broadly comparable and no material distinction justified exclusion. The limitation ground was left open. en-us Tue, 10 Mar 2026 00:00:00 +0530 Tue, 28 Apr 2026 19:51:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468323 A transfer pricing comparable must be functionally similar to the tested party under TNMM, including similarity in risk profile, asset base and operating model. Acropetal Technologies Ltd. was excluded because its low employee cost, outsourced and onsite development, R&D activity and acquisition-driven growth made it functionally different from the assessee's business support services. e4e Healthcare Business Services Pvt. Ltd. was included because its healthcare outsourcing and support services were broadly comparable and no material distinction justified exclusion. The limitation ground was left open. Case-Laws Income Tax Tue, 10 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468323