https://www.taxtmi.com/caselaws?id=468908 Persistent Systems Ltd. was found functionally dissimilar for transfer pricing benchmarking under the transactional net margin method because it was engaged in software products, software services and technology innovation, with material emphasis on product development and no reliable segmental bifurcation of product and service revenues. Broader functional similarity was treated as insufficient where material differences in business model remained. The earlier exclusion of the same company in the assessee's own case, as upheld by the jurisdictional High Court, supported exclusion, and the recalled earlier order had no continuing effect for this comparable. Persistent Systems Ltd. was therefore directed to be excluded from the final list of comparables. en-us Fri, 07 Feb 2025 00:00:00 +0530 Mon, 25 May 2026 20:05:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468908 Persistent Systems Ltd. was found functionally dissimilar for transfer pricing benchmarking under the transactional net margin method because it was engaged in software products, software services and technology innovation, with material emphasis on product development and no reliable segmental bifurcation of product and service revenues. Broader functional similarity was treated as insufficient where material differences in business model remained. The earlier exclusion of the same company in the assessee's own case, as upheld by the jurisdictional High Court, supported exclusion, and the recalled earlier order had no continuing effect for this comparable. Persistent Systems Ltd. was therefore directed to be excluded from the final list of comparables. Case-Laws Income Tax Fri, 07 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468908