https://www.taxtmi.com/caselaws?id=471968 Under the Transactional Net Margin Method, comparable companies must be functionally similar to the tested party. A mixed technical and software service provider without reliable segmental information cannot be benchmarked against a software-development service provider, particularly where an exceptionally high margin requires examination of normal business conditions; it should be excluded. Likewise, a company undertaking digital publishing, typesetting, digitisation, and content or product development performs knowledge-process functions rather than routine ITES and should be excluded. Transfer-pricing benchmarking must proceed using comparable sets stripped of functionally dissimilar entities. en-us Fri, 17 Jun 2022 00:00:00 +0530 Fri, 25 Sep 2026 10:56:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471968 Under the Transactional Net Margin Method, comparable companies must be functionally similar to the tested party. A mixed technical and software service provider without reliable segmental information cannot be benchmarked against a software-development service provider, particularly where an exceptionally high margin requires examination of normal business conditions; it should be excluded. Likewise, a company undertaking digital publishing, typesetting, digitisation, and content or product development performs knowledge-process functions rather than routine ITES and should be excluded. Transfer-pricing benchmarking must proceed using comparable sets stripped of functionally dissimilar entities. Case-Laws Income Tax Fri, 17 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471968