https://www.taxtmi.com/highlights?id=104164 Upper turnover filters in transfer-pricing comparable selection may be applied where differences in turnover, brand value, economies of scale, bargaining power and ownership of intangibles materially affect profitability and comparability. High-turnover software-development companies were treated as unsuitable comparables because their scale and functional profile differed from that of the tested party. The approach supports excluding enterprises exceeding the stated turnover threshold when scale-related factors distort an arm's-length comparison. en-us Fri, 25 Sep 2026 08:16:32 +0530 Fri, 25 Sep 2026 08:16:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=104164 Upper turnover filters in transfer-pricing comparable selection may be applied where differences in turnover, brand value, economies of scale, bargaining power and ownership of intangibles materially affect profitability and comparability. High-turnover software-development companies were treated as unsuitable comparables because their scale and functional profile differed from that of the tested party. The approach supports excluding enterprises exceeding the stated turnover threshold when scale-related factors distort an arm's-length comparison. Highlights Income Tax Fri, 25 Sep 2026 08:16:32 +0530 https://www.taxtmi.com/highlights?id=104164