https://www.taxtmi.com/caselaws?id=468944 For transfer pricing comparability, a company must be functionally similar to the tested captive service provider. Acropetal Technology Ltd. was excluded because it operated in engineering design and other services with substantial on-site activity and a materially different operating model, so it was not a reliable comparable. Infosys BPO was also excluded because its very high turnover, brand value and other intangibles could distort margins and make it unsuitable for a captive service provider of a different scale and profile. The Revenue's challenge failed, and the arm's length price was to be recomputed without those companies. en-us Fri, 08 Nov 2019 00:00:00 +0530 Tue, 26 May 2026 15:45:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468944 For transfer pricing comparability, a company must be functionally similar to the tested captive service provider. Acropetal Technology Ltd. was excluded because it operated in engineering design and other services with substantial on-site activity and a materially different operating model, so it was not a reliable comparable. Infosys BPO was also excluded because its very high turnover, brand value and other intangibles could distort margins and make it unsuitable for a captive service provider of a different scale and profile. The Revenue's challenge failed, and the arm's length price was to be recomputed without those companies. Case-Laws Income Tax Fri, 08 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468944