https://www.taxtmi.com/caselaws?id=800893 Functional comparability under the Transactional Net Margin Method requires assessment of a comparable's actual business and financial profile for the relevant year. An entity performing infrastructure management, network operations, cloud computing, engineering and quality-assurance services alongside software development cannot be benchmarked at entity level against a software-development service provider where reliable segmental revenue and results are unavailable. Comparable margins must be recomputed in accordance with directions issued under section 144C(5) after verification and revision of the comparable set. Outstanding-receivable interest adjustments require verification of domestic balances and a transaction-specific arm's length rate based on the associated enterprise's financial standing, creditworthiness, and comparable uncontrolled terms. en-us Wed, 30 Sep 2026 00:00:00 +0530 Tue, 13 Oct 2026 07:21:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800893 Functional comparability under the Transactional Net Margin Method requires assessment of a comparable's actual business and financial profile for the relevant year. An entity performing infrastructure management, network operations, cloud computing, engineering and quality-assurance services alongside software development cannot be benchmarked at entity level against a software-development service provider where reliable segmental revenue and results are unavailable. Comparable margins must be recomputed in accordance with directions issued under section 144C(5) after verification and revision of the comparable set. Outstanding-receivable interest adjustments require verification of domestic balances and a transaction-specific arm's length rate based on the associated enterprise's financial standing, creditworthiness, and comparable uncontrolled terms. Case-Laws Income Tax Wed, 30 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800893