https://www.taxtmi.com/caselaws?id=797222 Transfer-pricing comparability for software development services may apply an upper turnover filter of ten times the tested party's turnover. Material scale differences can affect the functions, assets and risks profile because significantly larger companies may benefit from economies of scale, stronger market position, valuable intangibles and diversified operations. Consistency with an earlier-year determination supports retaining the filter where facts and law remain unchanged. Companies exceeding the ten-times threshold should be excluded from the comparable set, and the arm's length price should be recomputed after allowing the assessee an opportunity to be heard. en-us Wed, 29 Jul 2026 00:00:00 +0530 Wed, 19 Aug 2026 08:20:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797222 Transfer-pricing comparability for software development services may apply an upper turnover filter of ten times the tested party's turnover. Material scale differences can affect the functions, assets and risks profile because significantly larger companies may benefit from economies of scale, stronger market position, valuable intangibles and diversified operations. Consistency with an earlier-year determination supports retaining the filter where facts and law remain unchanged. Companies exceeding the ten-times threshold should be excluded from the comparable set, and the arm's length price should be recomputed after allowing the assessee an opportunity to be heard. Case-Laws Income Tax Wed, 29 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797222