https://www.taxtmi.com/caselaws?id=471088 Under the transactional net margin method, an extraordinary prior-period gratuity provision arising from a changed actuarial recognition method must be excluded from operating-cost and operating-margin computation because it relates to earlier years; tax deductibility under Section 43B does not govern the profit level indicator. The arm's-length analysis must therefore be recomputed without that expenditure. Comparable entities must also satisfy turnover and functional-similarity filters. High-turnover entities exceeding the applicable threshold, and entities providing materially different services without segmental data, including software consultancy and voice-based call-centre operations, must be excluded from the comparable set for content-related services. en-us Mon, 26 May 2025 00:00:00 +0530 Thu, 20 Aug 2026 13:42:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471088 Under the transactional net margin method, an extraordinary prior-period gratuity provision arising from a changed actuarial recognition method must be excluded from operating-cost and operating-margin computation because it relates to earlier years; tax deductibility under Section 43B does not govern the profit level indicator. The arm's-length analysis must therefore be recomputed without that expenditure. Comparable entities must also satisfy turnover and functional-similarity filters. High-turnover entities exceeding the applicable threshold, and entities providing materially different services without segmental data, including software consultancy and voice-based call-centre operations, must be excluded from the comparable set for content-related services. Case-Laws Income Tax Mon, 26 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471088