https://www.taxtmi.com/caselaws?id=799434 TNMM benchmarking using an OP/OC profit level indicator requires reliable segmental profitability, including a demonstrated allocation of common operating expenses. A BPO segment with unallocated entity-level expenses may understate costs and overstate margins and should be excluded as unreliable. A separate software-development business does not disqualify an entity where distinct ITeS segment results are available and the retained segments are functionally comparable. Information collected from a proposed comparable supports benchmarking only if the relevant segmental financial data reliably reflects profitability. en-us Tue, 25 Aug 2026 00:00:00 +0530 Tue, 22 Sep 2026 08:17:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799434 TNMM benchmarking using an OP/OC profit level indicator requires reliable segmental profitability, including a demonstrated allocation of common operating expenses. A BPO segment with unallocated entity-level expenses may understate costs and overstate margins and should be excluded as unreliable. A separate software-development business does not disqualify an entity where distinct ITeS segment results are available and the retained segments are functionally comparable. Information collected from a proposed comparable supports benchmarking only if the relevant segmental financial data reliably reflects profitability. Case-Laws Income Tax Tue, 25 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799434