https://www.taxtmi.com/caselaws?id=469160 Transfer pricing comparability under TNMM required functional similarity, consistent aggregation of related party transactions, and reliable adjustments for material differences. In the software development segment, the Tribunal directed recomputation of the related party transaction filter on an aggregate basis, excluded several functionally dissimilar comparables, accepted cash profit level indicator, and remitted the risk adjustment and selected comparables for fresh consideration. In marketing support services, it excluded impugned comparables and directed implementation of the inclusion of Concept Public Relations India Ltd. Notional interest on trade receivables was remitted for recomputation under the earlier year framework. Depreciation on GST capitalised to asset cost was allowed, while goodwill depreciation from amalgamation was remitted for fresh adjudication. en-us Mon, 11 Sep 2023 00:00:00 +0530 Fri, 05 Jun 2026 17:49:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469160 Transfer pricing comparability under TNMM required functional similarity, consistent aggregation of related party transactions, and reliable adjustments for material differences. In the software development segment, the Tribunal directed recomputation of the related party transaction filter on an aggregate basis, excluded several functionally dissimilar comparables, accepted cash profit level indicator, and remitted the risk adjustment and selected comparables for fresh consideration. In marketing support services, it excluded impugned comparables and directed implementation of the inclusion of Concept Public Relations India Ltd. Notional interest on trade receivables was remitted for recomputation under the earlier year framework. Depreciation on GST capitalised to asset cost was allowed, while goodwill depreciation from amalgamation was remitted for fresh adjudication. Case-Laws Income Tax Mon, 11 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469160