https://www.taxtmi.com/highlights?id=103208 Transfer-pricing benchmarking for administrative and marketing support services requires functional similarity and adequate segmental data. Engineering consultancy, construction-related activities, trading and mixed sales-service operations, commission agency and technical services are unsuitable comparables; a different financial year alone does not require exclusion where an appropriate adjustment is possible. For IT-enabled services, outsourcing businesses without segmental information and knowledge-process outsourcing providers are functionally dissimilar. Proposed comparables needing review of segmental or financial data, including those affected by a service-income filter, require verification and fresh computation. Claimed comparable-margin corrections and risk adjustments depend on substantiation, factual reconciliation and consequential examination. en-us Sat, 29 Aug 2026 14:35:41 +0530 Sat, 29 Aug 2026 14:35:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103208 Transfer-pricing benchmarking for administrative and marketing support services requires functional similarity and adequate segmental data. Engineering consultancy, construction-related activities, trading and mixed sales-service operations, commission agency and technical services are unsuitable comparables; a different financial year alone does not require exclusion where an appropriate adjustment is possible. For IT-enabled services, outsourcing businesses without segmental information and knowledge-process outsourcing providers are functionally dissimilar. Proposed comparables needing review of segmental or financial data, including those affected by a service-income filter, require verification and fresh computation. Claimed comparable-margin corrections and risk adjustments depend on substantiation, factual reconciliation and consequential examination. Highlights Income Tax Sat, 29 Aug 2026 14:35:41 +0530 https://www.taxtmi.com/highlights?id=103208