https://www.taxtmi.com/caselaws?id=794596 Functional comparability is central to transfer pricing: entities engaged in pathology, radiology, imaging, healthcare, software development, data processing and contact-centre activities were held functionally dissimilar to a basic market research and testing service provider operating on a cost-plus, no-risk basis, so inappropriate comparables were excluded and the transfer pricing challenge succeeded. Depreciation on computer software was not finally rejected; it was restored for verification of whether the asset qualified for the claimed rate or only as an intangible asset at a lower rate. The disallowance under section 40(a)(ia) on international travel expenses was also remitted for factual verification of tax deduction and deposit, resulting in partial relief. en-us Tue, 09 Jun 2026 00:00:00 +0530 Wed, 08 Jul 2026 09:08:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794596 Functional comparability is central to transfer pricing: entities engaged in pathology, radiology, imaging, healthcare, software development, data processing and contact-centre activities were held functionally dissimilar to a basic market research and testing service provider operating on a cost-plus, no-risk basis, so inappropriate comparables were excluded and the transfer pricing challenge succeeded. Depreciation on computer software was not finally rejected; it was restored for verification of whether the asset qualified for the claimed rate or only as an intangible asset at a lower rate. The disallowance under section 40(a)(ia) on international travel expenses was also remitted for factual verification of tax deduction and deposit, resulting in partial relief. Case-Laws Income Tax Tue, 09 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794596