https://www.taxtmi.com/caselaws?id=793997 Transfer pricing benchmarking under TNMM required exclusion of functionally dissimilar comparables, including product-based, diversified, education-oriented and other non-matching entities, while suitable comparables could be added where functional parity existed. Working capital differences were treated as material to comparability and the adjustment was upheld to level the playing field. The analysis also required reworking segment margins, granting TDS credit after verification, and recomputing interest in accordance with law. Penalty initiation was treated as premature and consequential. The overall effect was substantial relief through recomputation and revised comparable selection across the subscription, services, software development and IT enabled services segments. en-us Mon, 30 Mar 2026 00:00:00 +0530 Sat, 27 Jun 2026 08:33:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793997 Transfer pricing benchmarking under TNMM required exclusion of functionally dissimilar comparables, including product-based, diversified, education-oriented and other non-matching entities, while suitable comparables could be added where functional parity existed. Working capital differences were treated as material to comparability and the adjustment was upheld to level the playing field. The analysis also required reworking segment margins, granting TDS credit after verification, and recomputing interest in accordance with law. Penalty initiation was treated as premature and consequential. The overall effect was substantial relief through recomputation and revised comparable selection across the subscription, services, software development and IT enabled services segments. Case-Laws Income Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793997