https://www.taxtmi.com/highlights?id=104939 Functional comparability in transfer pricing is a factual, data-driven assessment that must conform to Rule 10B. The High Court upheld the exclusion of an outsourced-service provider from the comparable set because outsourcing a major portion of its work made it functionally dissimilar to the assessee. The Revenue produced no contrary material and failed to establish perversity, reliance on irrelevant material, or exclusion of relevant material in the Tribunal's factual finding. The substantial questions of law were answered for the assessee, and the Revenue's appeal was dismissed. en-us Wed, 14 Oct 2026 06:17:13 +0530 Wed, 14 Oct 2026 06:17:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=104939 Functional comparability in transfer pricing is a factual, data-driven assessment that must conform to Rule 10B. The High Court upheld the exclusion of an outsourced-service provider from the comparable set because outsourcing a major portion of its work made it functionally dissimilar to the assessee. The Revenue produced no contrary material and failed to establish perversity, reliance on irrelevant material, or exclusion of relevant material in the Tribunal's factual finding. The substantial questions of law were answered for the assessee, and the Revenue's appeal was dismissed. Highlights Income Tax Wed, 14 Oct 2026 06:17:13 +0530 https://www.taxtmi.com/highlights?id=104939