https://www.taxtmi.com/caselaws?id=471963 Transfer-pricing benchmarking requires non-operating other income to be excluded when applying an ITES service-income filter. A company whose operating service revenue is entirely from ITES may remain comparable, while expenses directly attributable to rental income, including relevant depreciation and property costs, must be verified and excluded from operating expenses when calculating the Profit Level Indicator. Functional comparability of an outsourced publishing-services provider is determined primarily from its own annual-report profile; group-level prospectus descriptions do not establish high-end content, product-development, or knowledge-process functions. en-us Tue, 15 Apr 2025 00:00:00 +0530 Thu, 24 Sep 2026 19:22:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471963 Transfer-pricing benchmarking requires non-operating other income to be excluded when applying an ITES service-income filter. A company whose operating service revenue is entirely from ITES may remain comparable, while expenses directly attributable to rental income, including relevant depreciation and property costs, must be verified and excluded from operating expenses when calculating the Profit Level Indicator. Functional comparability of an outsourced publishing-services provider is determined primarily from its own annual-report profile; group-level prospectus descriptions do not establish high-end content, product-development, or knowledge-process functions. Case-Laws Income Tax Tue, 15 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471963