https://www.taxtmi.com/caselaws?id=792013 Transfer pricing comparability requires both functional similarity under the FAR analysis and a materially comparable scale of operations. An export-earning filter cannot by itself justify including an e-publishing company as an IT-enabled services comparable where its functional profile requires separate examination. Extreme turnover disparity may also undermine comparability where the scale difference materially affects operating structure, economic profile and margins. The High Court's stated conclusions favour the Revenue: the first comparable required reassessment of functional similarity, and the low-turnover company was not a proper comparable. en-us Mon, 18 May 2026 00:00:00 +0530 Thu, 21 May 2026 08:30:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792013 Transfer pricing comparability requires both functional similarity under the FAR analysis and a materially comparable scale of operations. An export-earning filter cannot by itself justify including an e-publishing company as an IT-enabled services comparable where its functional profile requires separate examination. Extreme turnover disparity may also undermine comparability where the scale difference materially affects operating structure, economic profile and margins. The High Court's stated conclusions favour the Revenue: the first comparable required reassessment of functional similarity, and the low-turnover company was not a proper comparable. Case-Laws Income Tax Mon, 18 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792013