https://www.taxtmi.com/caselaws?id=792973 Functional comparability in transfer pricing must be tested on a year-specific FAR basis, and captive software service providers may exclude companies engaged in diversified operations, product engineering, consulting, IP-led services, or lacking segmental data. A company rejected only for a different financial year end may still be included if its public data can be reasonably extrapolated for the relevant year. Working capital differences materially affect margins, so adjustment may be granted using annual report opening and closing balances even without daily or monthly third-party data. Where working capital adjustment already captures receivables impact, a separate trade receivables adjustment may not survive unless an unabsorbed pricing effect remains; for residual benchmarking, LIBOR plus 200 basis points and a 60-day credit period were applied. en-us Fri, 29 May 2026 00:00:00 +0530 Sat, 06 Jun 2026 08:42:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792973 Functional comparability in transfer pricing must be tested on a year-specific FAR basis, and captive software service providers may exclude companies engaged in diversified operations, product engineering, consulting, IP-led services, or lacking segmental data. A company rejected only for a different financial year end may still be included if its public data can be reasonably extrapolated for the relevant year. Working capital differences materially affect margins, so adjustment may be granted using annual report opening and closing balances even without daily or monthly third-party data. Where working capital adjustment already captures receivables impact, a separate trade receivables adjustment may not survive unless an unabsorbed pricing effect remains; for residual benchmarking, LIBOR plus 200 basis points and a 60-day credit period were applied. Case-Laws Income Tax Fri, 29 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792973