https://www.taxtmi.com/caselaws?id=798097 Transfer-pricing comparables for ITES/BPO transactions must be functionally and economically comparable. A consistently accepted comparable may be retained, while entities with materially different outsourcing models, substantially greater scale or brand value, brand and goodwill ownership, unavailable segmental data, or high-end KPO and engineering-design functions should be excluded. Such differences can render an arm's length price adjustment unsustainable. Call-centre, back-office and data-processing services fall within notified computer-software-related services under Section 10A where they involve customised electronic data or similar notified services. Eligibility is reinforced where the activities remain unchanged from prior years in which the deduction was accepted. en-us Tue, 25 Aug 2026 00:00:00 +0530 Wed, 02 Sep 2026 08:30:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798097 Transfer-pricing comparables for ITES/BPO transactions must be functionally and economically comparable. A consistently accepted comparable may be retained, while entities with materially different outsourcing models, substantially greater scale or brand value, brand and goodwill ownership, unavailable segmental data, or high-end KPO and engineering-design functions should be excluded. Such differences can render an arm's length price adjustment unsustainable. Call-centre, back-office and data-processing services fall within notified computer-software-related services under Section 10A where they involve customised electronic data or similar notified services. Eligibility is reinforced where the activities remain unchanged from prior years in which the deduction was accepted. Case-Laws Income Tax Tue, 25 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798097