https://www.taxtmi.com/caselaws?id=800209 Functional comparability under the Transactional Net Margin Method requires broadly similar functions, assets and risks despite tolerance for routine differences in costs, turnover and commercial conditions. Software-product, licensing, specialised-design or proprietary-intellectual-property businesses without reliable segmental data should not be compared at entity level with routine software-support and IT-enabled service providers. A different accounting year does not preclude comparability where audited quarterly data permits financial-year recomputation. Draft and final assessments following a Transfer Pricing Officer reference must comply with the extended limitation period and the prescribed Dispute Resolution Panel process. Foreign tax credit includes income exempt under section 10AA, subject to the treaty ceiling for Indian tax attributable to source-State taxable income. en-us Mon, 24 Aug 2026 00:00:00 +0530 Sat, 03 Oct 2026 09:32:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800209 Functional comparability under the Transactional Net Margin Method requires broadly similar functions, assets and risks despite tolerance for routine differences in costs, turnover and commercial conditions. Software-product, licensing, specialised-design or proprietary-intellectual-property businesses without reliable segmental data should not be compared at entity level with routine software-support and IT-enabled service providers. A different accounting year does not preclude comparability where audited quarterly data permits financial-year recomputation. Draft and final assessments following a Transfer Pricing Officer reference must comply with the extended limitation period and the prescribed Dispute Resolution Panel process. Foreign tax credit includes income exempt under section 10AA, subject to the treaty ceiling for Indian tax attributable to source-State taxable income. Case-Laws Income Tax Mon, 24 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800209