https://www.taxtmi.com/caselaws?id=793215 Under TNMM, comparables must be selected through a reasoned FAR analysis, and a cost-plus captive service provider rendering routine human resource support services cannot be recharacterised as a high-end KPO entity merely because human resources appear in the illustrative KPO definition. The assessee's benchmarking, supported by quantitative and qualitative filters, was accepted because the same comparables continued to emerge even after modified filters were applied. The TPO's substitution of functionally dissimilar entities engaged in consulting, advisory, marketing, public relations and other diversified services was treated as impermissible cherry picking, and the transfer pricing adjustment was therefore deleted on the basis that the international transactions were at arm's length. en-us Mon, 20 Apr 2026 00:00:00 +0530 Thu, 11 Jun 2026 08:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793215 Under TNMM, comparables must be selected through a reasoned FAR analysis, and a cost-plus captive service provider rendering routine human resource support services cannot be recharacterised as a high-end KPO entity merely because human resources appear in the illustrative KPO definition. The assessee's benchmarking, supported by quantitative and qualitative filters, was accepted because the same comparables continued to emerge even after modified filters were applied. The TPO's substitution of functionally dissimilar entities engaged in consulting, advisory, marketing, public relations and other diversified services was treated as impermissible cherry picking, and the transfer pricing adjustment was therefore deleted on the basis that the international transactions were at arm's length. Case-Laws Income Tax Mon, 20 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793215