https://www.taxtmi.com/caselaws?id=469954 Functional comparability governs transfer pricing under TNMM: companies engaged in software products, KPO, engineering and consulting, diversified activities, or lacking reliable segmental data were held unsuitable for comparison with a routine software development service provider, and the ALP was to be recomputed after excluding those comparables. In the marketing support services segment, ICC International Agencies Ltd. was excluded because it earned trading income and held inventories, making it functionally dissimilar to a service provider; working capital adjustment was also directed to be examined and granted after hearing the assessee. Transfer pricing additions were thus not sustained in full. en-us Fri, 04 Sep 2020 00:00:00 +0530 Fri, 10 Jul 2026 17:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469954 Functional comparability governs transfer pricing under TNMM: companies engaged in software products, KPO, engineering and consulting, diversified activities, or lacking reliable segmental data were held unsuitable for comparison with a routine software development service provider, and the ALP was to be recomputed after excluding those comparables. In the marketing support services segment, ICC International Agencies Ltd. was excluded because it earned trading income and held inventories, making it functionally dissimilar to a service provider; working capital adjustment was also directed to be examined and granted after hearing the assessee. Transfer pricing additions were thus not sustained in full. Case-Laws Income Tax Fri, 04 Sep 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469954