https://www.taxtmi.com/caselaws?id=791011 Turnover is a material transfer pricing comparability factor because scale can affect profitability, market position, bargaining power, asset base, risk profile and functional comparability. In software development benchmarking, comparables with disproportionately high turnover may be excluded when the tested party is a captive service provider operating at a much lower scale, and an appropriate upper turnover filter should be applied. Inclusion of comparables such as I2T2 India Limited and Cigniti Technologies Limited cannot be directed without fresh verification of the relevant year's financials, functional profile, segmental data and other quantitative filters. The turnover-filter issue was resolved in favour of the assessee, while the other comparable-selection issue required fresh examination. en-us Tue, 24 Feb 2026 00:00:00 +0530 Mon, 04 May 2026 13:08:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791011 Turnover is a material transfer pricing comparability factor because scale can affect profitability, market position, bargaining power, asset base, risk profile and functional comparability. In software development benchmarking, comparables with disproportionately high turnover may be excluded when the tested party is a captive service provider operating at a much lower scale, and an appropriate upper turnover filter should be applied. Inclusion of comparables such as I2T2 India Limited and Cigniti Technologies Limited cannot be directed without fresh verification of the relevant year's financials, functional profile, segmental data and other quantitative filters. The turnover-filter issue was resolved in favour of the assessee, while the other comparable-selection issue required fresh examination. Case-Laws Income Tax Tue, 24 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791011