https://www.taxtmi.com/caselaws?id=472541 Transfer-pricing comparability under the transactional net margin method requires a separate functions, assets and risks analysis for every proposed comparable. Retaining Infosys BPO Ltd., where its suitability was not challenged, does not establish the functional comparability of other high-end ITES entities. Low-end ITES/BPO providers should not be benchmarked against Eclerx Services Ltd., whose analytics and knowledge-process outsourcing functions materially differ. ICRA Techno Analytics Ltd.'s segment, involving business analytics, operational solutions and internally developed customised software, is likewise functionally dissimilar. The appropriate comparable set therefore excludes dissimilar KPO and business-analytics entities when determining the arm's-length price. en-us Fri, 08 Feb 2019 00:00:00 +0530 Thu, 15 Oct 2026 17:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472541 Transfer-pricing comparability under the transactional net margin method requires a separate functions, assets and risks analysis for every proposed comparable. Retaining Infosys BPO Ltd., where its suitability was not challenged, does not establish the functional comparability of other high-end ITES entities. Low-end ITES/BPO providers should not be benchmarked against Eclerx Services Ltd., whose analytics and knowledge-process outsourcing functions materially differ. ICRA Techno Analytics Ltd.'s segment, involving business analytics, operational solutions and internally developed customised software, is likewise functionally dissimilar. The appropriate comparable set therefore excludes dissimilar KPO and business-analytics entities when determining the arm's-length price. Case-Laws Income Tax Fri, 08 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472541