https://www.taxtmi.com/caselaws?id=468455 In transfer pricing comparability analysis, only companies with functional similarity and reliable segmental data can be retained as comparables for captive software development and ITeS service providers; entities engaged in diversified, product-led, R&D-intensive or higher-end KPO functions were excluded, while a few companies were remitted for fresh verification. For the software development segment, Persistent Systems & Solutions Ltd., Acropetal Technologies Ltd., E-Infochips Ltd. and ICRA Techno Analytics Ltd. were excluded, and E-Zest Solutions Ltd. was remanded. For the ITeS segment, Accentia Technologies Ltd., Acropetal Technologies Ltd. and Jeevan Scientific Technologies Ltd. were excluded, and ICRA Online Ltd. was remanded. Negative working capital adjustment was rejected because the captive provider did not bear working capital risk. en-us Mon, 06 Dec 2021 00:00:00 +0530 Thu, 07 May 2026 12:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468455 In transfer pricing comparability analysis, only companies with functional similarity and reliable segmental data can be retained as comparables for captive software development and ITeS service providers; entities engaged in diversified, product-led, R&D-intensive or higher-end KPO functions were excluded, while a few companies were remitted for fresh verification. For the software development segment, Persistent Systems & Solutions Ltd., Acropetal Technologies Ltd., E-Infochips Ltd. and ICRA Techno Analytics Ltd. were excluded, and E-Zest Solutions Ltd. was remanded. For the ITeS segment, Accentia Technologies Ltd., Acropetal Technologies Ltd. and Jeevan Scientific Technologies Ltd. were excluded, and ICRA Online Ltd. was remanded. Negative working capital adjustment was rejected because the captive provider did not bear working capital risk. Case-Laws Income Tax Mon, 06 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468455