https://www.taxtmi.com/caselaws?id=794886 Transfer pricing comparability must use reliable financial data and functional, economic, and scale-based analysis. A company following a different accounting year cannot be excluded where published quarterly results permit construction of the relevant year and the FAR profile is comparable. Rheal Software Pvt. Ltd. could not be rejected under the persistent loss filter without a defined and consistently applied criterion. Very high-turnover, branded companies were not comparable to a smaller captive software service provider because scale and brand advantages affected margins. Delayed foreign-currency receivables had to be benchmarked using an appropriate LIBOR-based rate rather than SBI PLR, requiring recomputation of the transfer pricing adjustment. en-us Wed, 28 Jan 2026 00:00:00 +0530 Tue, 14 Jul 2026 08:26:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794886 Transfer pricing comparability must use reliable financial data and functional, economic, and scale-based analysis. A company following a different accounting year cannot be excluded where published quarterly results permit construction of the relevant year and the FAR profile is comparable. Rheal Software Pvt. Ltd. could not be rejected under the persistent loss filter without a defined and consistently applied criterion. Very high-turnover, branded companies were not comparable to a smaller captive software service provider because scale and brand advantages affected margins. Delayed foreign-currency receivables had to be benchmarked using an appropriate LIBOR-based rate rather than SBI PLR, requiring recomputation of the transfer pricing adjustment. Case-Laws Income Tax Wed, 28 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794886