https://www.taxtmi.com/caselaws?id=792494 Turnover was treated as a relevant comparability filter in software development transfer pricing, and a ten-times range on either side of the assessee's turnover was accepted. The exclusion of Thirdware Solutions Ltd., Kals Information Systems Ltd., Cigniti Technologies Ltd., R S Software (India) Ltd., Inteq Software Pvt. Ltd., Infobeans Technologies Ltd., Rheal Software Pvt. Ltd. and CG-VAK Software & Exports Ltd. was upheld on functional dissimilarity and related comparability grounds, while Evoke Technologies Ltd. was retained because its audited financials permitted computation of the profit level indicator from Indian operations. It was also stated that benchmarking under TNMM does not require more than one comparable, so a limited set may be used if functionally comparable and otherwise filter-compliant. en-us Fri, 24 Apr 2026 00:00:00 +0530 Thu, 28 May 2026 12:32:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792494 Turnover was treated as a relevant comparability filter in software development transfer pricing, and a ten-times range on either side of the assessee's turnover was accepted. The exclusion of Thirdware Solutions Ltd., Kals Information Systems Ltd., Cigniti Technologies Ltd., R S Software (India) Ltd., Inteq Software Pvt. Ltd., Infobeans Technologies Ltd., Rheal Software Pvt. Ltd. and CG-VAK Software & Exports Ltd. was upheld on functional dissimilarity and related comparability grounds, while Evoke Technologies Ltd. was retained because its audited financials permitted computation of the profit level indicator from Indian operations. It was also stated that benchmarking under TNMM does not require more than one comparable, so a limited set may be used if functionally comparable and otherwise filter-compliant. Case-Laws Income Tax Fri, 24 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792494