https://www.taxtmi.com/caselaws?id=469177 Under TNMM, a comparable must satisfy broad but real functional similarity for arm's length benchmarking. The Tribunal held that Adecco Peopleone India Pvt. Ltd. and Alliance Comnet Ltd. were not comparable to the assessee's logistics and business support services because their functions involved HR staffing, recruitment, ITES and document management; both were excluded. It also held that Killick Agencies & Marketing Ltd. was not comparable to the assessee's captive support services because it operated in a different marine-industry commission and after-sales business; it was excluded. The assessee therefore succeeded on the transfer-pricing comparability disputes in both matters. en-us Fri, 16 Sep 2022 00:00:00 +0530 Mon, 08 Jun 2026 14:39:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469177 Under TNMM, a comparable must satisfy broad but real functional similarity for arm's length benchmarking. The Tribunal held that Adecco Peopleone India Pvt. Ltd. and Alliance Comnet Ltd. were not comparable to the assessee's logistics and business support services because their functions involved HR staffing, recruitment, ITES and document management; both were excluded. It also held that Killick Agencies & Marketing Ltd. was not comparable to the assessee's captive support services because it operated in a different marine-industry commission and after-sales business; it was excluded. The assessee therefore succeeded on the transfer-pricing comparability disputes in both matters. Case-Laws Income Tax Fri, 16 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469177