https://www.taxtmi.com/caselaws?id=800878 Transfer-pricing comparability for captive, limited-risk software-development service providers requires alignment of functions, assets and risks under FAR analysis. Diversified companies owning substantial brands, goodwill, patents and other intangibles, incurring significant research and development expenditure, and assuming substantial business and intellectual-property risks are materially different from cost-plus captive providers. Where standalone segmental information for comparable service activities is unavailable, such companies should be excluded from the comparable set. The transfer-pricing adjustment requires recomputation using functionally comparable entities. en-us Wed, 09 Sep 2026 00:00:00 +0530 Tue, 13 Oct 2026 07:21:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800878 Transfer-pricing comparability for captive, limited-risk software-development service providers requires alignment of functions, assets and risks under FAR analysis. Diversified companies owning substantial brands, goodwill, patents and other intangibles, incurring significant research and development expenditure, and assuming substantial business and intellectual-property risks are materially different from cost-plus captive providers. Where standalone segmental information for comparable service activities is unavailable, such companies should be excluded from the comparable set. The transfer-pricing adjustment requires recomputation using functionally comparable entities. Case-Laws Income Tax Wed, 09 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800878