https://www.taxtmi.com/caselaws?id=791089 Transfer pricing comparability under TNMM requires a matching FAR profile, so materially different scale, mixed functions and unreliable segmental data can justify exclusion of an entity from the comparables set. High-turnover companies may be rejected where their size, market position and economies of scale make them unlike a captive service provider. In the software development segment, entities engaged in product-based, diversified or multiple activities without dependable segmental break-up were treated as functionally dissimilar, while a service-heavy company with substantially all revenue from software services was retained. In marketing support services, indenting, commission and trading activities were treated as dissimilar, whereas advertising agency services were regarded as broadly comparable to marketing support functions. en-us Thu, 12 Mar 2026 00:00:00 +0530 Mon, 04 May 2026 15:16:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791089 Transfer pricing comparability under TNMM requires a matching FAR profile, so materially different scale, mixed functions and unreliable segmental data can justify exclusion of an entity from the comparables set. High-turnover companies may be rejected where their size, market position and economies of scale make them unlike a captive service provider. In the software development segment, entities engaged in product-based, diversified or multiple activities without dependable segmental break-up were treated as functionally dissimilar, while a service-heavy company with substantially all revenue from software services was retained. In marketing support services, indenting, commission and trading activities were treated as dissimilar, whereas advertising agency services were regarded as broadly comparable to marketing support functions. Case-Laws Income Tax Thu, 12 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791089