https://www.taxtmi.com/caselaws?id=799125 Functional similarity is the primary criterion for selecting comparables under the Transactional Net Margin Method for routine IT-enabled back-office services; companies performing specialised, higher-value services should be excluded despite meeting quantitative filters. Employee-cost filters cannot be applied mechanically where costs are embedded in service expenses or disclosed only at entity level; functionally similar companies should not be rejected solely on that basis. Outstanding receivables may constitute an international transaction, but a separate notional-interest adjustment requires proof of an independent financing arrangement and economic benefit beyond working-capital effects already reflected in the profit-level indicator. The arm's length price is recomputed using the revised comparable set without a separate receivables adjustment. en-us Tue, 21 Jul 2026 00:00:00 +0530 Thu, 17 Sep 2026 07:52:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799125 Functional similarity is the primary criterion for selecting comparables under the Transactional Net Margin Method for routine IT-enabled back-office services; companies performing specialised, higher-value services should be excluded despite meeting quantitative filters. Employee-cost filters cannot be applied mechanically where costs are embedded in service expenses or disclosed only at entity level; functionally similar companies should not be rejected solely on that basis. Outstanding receivables may constitute an international transaction, but a separate notional-interest adjustment requires proof of an independent financing arrangement and economic benefit beyond working-capital effects already reflected in the profit-level indicator. The arm's length price is recomputed using the revised comparable set without a separate receivables adjustment. Case-Laws Income Tax Tue, 21 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799125