https://www.taxtmi.com/caselaws?id=469138 Transfer pricing for a low-risk captive software development service provider must be tested on functional similarity, assets employed, risks assumed, scale, intangibles, R&D intensity and segmental data; companies that are materially larger, IP-led, diversified or lacking reliable segmental information may be excluded, while a different financial year end does not by itself disqualify a comparable if results can be reasonably extrapolated. Once scrutiny proceedings begin with notice under section 143(2), a disallowance made only through section 143(1) processing for leave encashment cannot be sustained in that manner. A challenge to initiation of penalty proceedings under section 270A was treated as premature. en-us Wed, 12 Nov 2025 00:00:00 +0530 Wed, 03 Jun 2026 16:55:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469138 Transfer pricing for a low-risk captive software development service provider must be tested on functional similarity, assets employed, risks assumed, scale, intangibles, R&D intensity and segmental data; companies that are materially larger, IP-led, diversified or lacking reliable segmental information may be excluded, while a different financial year end does not by itself disqualify a comparable if results can be reasonably extrapolated. Once scrutiny proceedings begin with notice under section 143(2), a disallowance made only through section 143(1) processing for leave encashment cannot be sustained in that manner. A challenge to initiation of penalty proceedings under section 270A was treated as premature. Case-Laws Income Tax Wed, 12 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469138