https://www.taxtmi.com/caselaws?id=797999 Functional comparability in transfer-pricing benchmarking requires exclusion of software entities performing enterprise transformation, product sales, onsite services, product development, or research and development activities where their functions materially differ from routine software development support services. Two other entities providing substantially similar software services require fresh comparability review. Eligibility of another proposed comparable requires verification of related-party transactions against the applicable 25% filter. Working capital adjustment claims for software development support and sales and marketing support services require fresh examination. Benchmarking must be recomputed after the exclusions and fresh determinations. en-us Tue, 04 Aug 2026 00:00:00 +0530 Tue, 01 Sep 2026 08:26:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797999 Functional comparability in transfer-pricing benchmarking requires exclusion of software entities performing enterprise transformation, product sales, onsite services, product development, or research and development activities where their functions materially differ from routine software development support services. Two other entities providing substantially similar software services require fresh comparability review. Eligibility of another proposed comparable requires verification of related-party transactions against the applicable 25% filter. Working capital adjustment claims for software development support and sales and marketing support services require fresh examination. Benchmarking must be recomputed after the exclusions and fresh determinations. Case-Laws Income Tax Tue, 04 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797999