https://www.taxtmi.com/caselaws?id=797458 Transactional net margin method comparables for captive data-processing and software-development services must be functionally and economically similar. Rule 10B(4) permits use of data from the two preceding years; a company is not a persistent loss-maker merely because it incurred losses in some relevant years, and a differing accounting year alone does not require exclusion where quarterly data can be extrapolated. Companies with materially different business models, substantial outsourcing, high-end services, software products, diversified licensing activities, significant brands or intangibles, entrepreneurial scale, or unreliable segmental data should be excluded. Repair and maintenance provisions require verification of supporting evidence, subsequent crystallisation and reversal, consistent with DRP directions. en-us Fri, 20 Feb 2026 00:00:00 +0530 Sat, 22 Aug 2026 10:33:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797458 Transactional net margin method comparables for captive data-processing and software-development services must be functionally and economically similar. Rule 10B(4) permits use of data from the two preceding years; a company is not a persistent loss-maker merely because it incurred losses in some relevant years, and a differing accounting year alone does not require exclusion where quarterly data can be extrapolated. Companies with materially different business models, substantial outsourcing, high-end services, software products, diversified licensing activities, significant brands or intangibles, entrepreneurial scale, or unreliable segmental data should be excluded. Repair and maintenance provisions require verification of supporting evidence, subsequent crystallisation and reversal, consistent with DRP directions. Case-Laws Income Tax Fri, 20 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797458