https://www.taxtmi.com/caselaws?id=800000 Functional comparability under the Transactional Net Margin Method requires exclusion of software companies with mixed product and service revenue lacking reliable segmental data, materially different functions, or brand value and scale affecting profitability. An onsite filter may be used to identify suitable comparables for software development services where no basis establishes that it is inappropriate. The DRP may apply a new filter consistent with accepted comparability principles and direct the inclusion or exclusion of comparables to determine the correct arm's length price. The challenged exclusions and approved filters remain effective for arm's length pricing. en-us Mon, 21 Sep 2026 00:00:00 +0530 Wed, 30 Sep 2026 08:41:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800000 Functional comparability under the Transactional Net Margin Method requires exclusion of software companies with mixed product and service revenue lacking reliable segmental data, materially different functions, or brand value and scale affecting profitability. An onsite filter may be used to identify suitable comparables for software development services where no basis establishes that it is inappropriate. The DRP may apply a new filter consistent with accepted comparability principles and direct the inclusion or exclusion of comparables to determine the correct arm's length price. The challenged exclusions and approved filters remain effective for arm's length pricing. Case-Laws Income Tax Mon, 21 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800000