https://www.taxtmi.com/caselaws?id=470700 Merger-related goodwill amortisation is treated as a non-operating expense for transfer-pricing operating-margin purposes because it is abnormal, non-recurring and unrelated to the provision of IT services; it must therefore be excluded from operating costs. Companies engaged in diversified high-end, consulting, analytics, product-engineering or digital services, with significant intangibles, absent segmental data, supernormal profits or excessive turnover, are unsuitable comparables for a captive IT-service provider and must be removed from the comparable set. Rule 46A does not apply where segmental information was furnished during assessment and later material merely clarifies that approach; no remand report is required. en-us Fri, 06 Jun 2025 00:00:00 +0530 Tue, 04 Aug 2026 20:51:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470700 Merger-related goodwill amortisation is treated as a non-operating expense for transfer-pricing operating-margin purposes because it is abnormal, non-recurring and unrelated to the provision of IT services; it must therefore be excluded from operating costs. Companies engaged in diversified high-end, consulting, analytics, product-engineering or digital services, with significant intangibles, absent segmental data, supernormal profits or excessive turnover, are unsuitable comparables for a captive IT-service provider and must be removed from the comparable set. Rule 46A does not apply where segmental information was furnished during assessment and later material merely clarifies that approach; no remand report is required. Case-Laws Income Tax Fri, 06 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470700