https://www.taxtmi.com/caselaws?id=791489 Transfer pricing comparability for a captive low-risk software development and ITeS provider requires exclusion of entities with materially different functions, strong brand value, significant intangibles, product-based or high-end KPO operations, or unreliable segmental data. In the software development segment, several large or functionally dissimilar companies were identified as not reliably comparable, while Tata Elxsi Limited and Persistent Systems Private Limited were left for fresh consideration on remand. In the ITeS segment, comparables engaged in specialised services or affected by extraordinary events such as amalgamation, demerger or acquisition were also treated as unsuitable. The analysis emphasises functional similarity, reliable margins and year-specific comparability as the governing transfer pricing standards. en-us Fri, 08 May 2026 00:00:00 +0530 Tue, 12 May 2026 08:50:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791489 Transfer pricing comparability for a captive low-risk software development and ITeS provider requires exclusion of entities with materially different functions, strong brand value, significant intangibles, product-based or high-end KPO operations, or unreliable segmental data. In the software development segment, several large or functionally dissimilar companies were identified as not reliably comparable, while Tata Elxsi Limited and Persistent Systems Private Limited were left for fresh consideration on remand. In the ITeS segment, comparables engaged in specialised services or affected by extraordinary events such as amalgamation, demerger or acquisition were also treated as unsuitable. The analysis emphasises functional similarity, reliable margins and year-specific comparability as the governing transfer pricing standards. Case-Laws Income Tax Fri, 08 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791489