https://www.taxtmi.com/caselaws?id=470151 Transfer-pricing comparability must rest on actual functions performed and reliable segmental results. Software-product developers, bio-informatics and research entities, and companies owning significant intellectual property or intangibles are not comparable to captive software-development service providers. Similarly, seismic, infrastructure, engineering, architectural and technical consultancy providers are functionally distinct from sales and post-sales support service providers. The Tribunal's exclusions were sustained because its findings of functional dissimilarity and unavailable segmental information were supported by the record and not perverse. Concurrent factual findings on comparability should not be disturbed absent perversity. en-us Wed, 05 Feb 2020 00:00:00 +0530 Fri, 17 Jul 2026 18:22:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470151 Transfer-pricing comparability must rest on actual functions performed and reliable segmental results. Software-product developers, bio-informatics and research entities, and companies owning significant intellectual property or intangibles are not comparable to captive software-development service providers. Similarly, seismic, infrastructure, engineering, architectural and technical consultancy providers are functionally distinct from sales and post-sales support service providers. The Tribunal's exclusions were sustained because its findings of functional dissimilarity and unavailable segmental information were supported by the record and not perverse. Concurrent factual findings on comparability should not be disturbed absent perversity. Case-Laws Income Tax Wed, 05 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470151