https://www.taxtmi.com/caselaws?id=800234 Transactional Net Margin Method benchmarking for administrative support services requires comparables to be functionally similar and capable of meaningful comparison after considering scale, risk profile, intangibles, brand value, service nature and financial stability. Entities with substantially higher turnover, diversified or high-end services, significant intangible or brand advantages, abnormal or volatile results, or functional differences must be excluded. Web-based software development and high-end analytical and research service providers were unsuitable. After their exclusion, the remaining comparable margins were lower than the tested party's margin, so no upward transfer-pricing adjustment was warranted. en-us Fri, 25 Sep 2026 00:00:00 +0530 Sat, 03 Oct 2026 09:32:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800234 Transactional Net Margin Method benchmarking for administrative support services requires comparables to be functionally similar and capable of meaningful comparison after considering scale, risk profile, intangibles, brand value, service nature and financial stability. Entities with substantially higher turnover, diversified or high-end services, significant intangible or brand advantages, abnormal or volatile results, or functional differences must be excluded. Web-based software development and high-end analytical and research service providers were unsuitable. After their exclusion, the remaining comparable margins were lower than the tested party's margin, so no upward transfer-pricing adjustment was warranted. Case-Laws Income Tax Fri, 25 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800234