https://www.taxtmi.com/caselaws?id=799700 Transfer-pricing comparability requires alignment with Rule 10B, including consideration of turnover, brand value, economies of scale, bargaining power and ownership of intangibles where those factors materially affect profitability. An upper turnover filter may therefore support exclusion of high-turnover software-development comparables that are materially larger and functionally dissimilar. A question concerning comparables that was not raised before the Tribunal does not arise for consideration at the subsequent stage. The exclusion of identified high-turnover comparables remains sustainable on comparability grounds. en-us Thu, 10 Sep 2026 00:00:00 +0530 Fri, 25 Sep 2026 08:16:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799700 Transfer-pricing comparability requires alignment with Rule 10B, including consideration of turnover, brand value, economies of scale, bargaining power and ownership of intangibles where those factors materially affect profitability. An upper turnover filter may therefore support exclusion of high-turnover software-development comparables that are materially larger and functionally dissimilar. A question concerning comparables that was not raised before the Tribunal does not arise for consideration at the subsequent stage. The exclusion of identified high-turnover comparables remains sustainable on comparability grounds. Case-Laws Income Tax Thu, 10 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799700