https://www.taxtmi.com/caselaws?id=793107 Transfer pricing comparability must be based on functional similarity and reliable segmental data: Cyber Media Research Limited was retained as a comparable for a support-services provider, while Apitco Limited and BVG India Limited were excluded because government ownership, divergent service profiles and absence of suitable segmental data undermined comparability. The claim that reversal of forex loss had been taxed twice was not finally accepted on the available record and was restored for fresh factual verification after examination of the books, computations and supporting material. The discussion also notes that factual claims affecting taxable income require verification before relief is granted. en-us Wed, 20 May 2026 00:00:00 +0530 Tue, 09 Jun 2026 07:50:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793107 Transfer pricing comparability must be based on functional similarity and reliable segmental data: Cyber Media Research Limited was retained as a comparable for a support-services provider, while Apitco Limited and BVG India Limited were excluded because government ownership, divergent service profiles and absence of suitable segmental data undermined comparability. The claim that reversal of forex loss had been taxed twice was not finally accepted on the available record and was restored for fresh factual verification after examination of the books, computations and supporting material. The discussion also notes that factual claims affecting taxable income require verification before relief is granted. Case-Laws Income Tax Wed, 20 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793107