https://www.taxtmi.com/caselaws?id=473022 Transfer-pricing benchmarking requires comparable companies to be functionally similar and reasonably comparable in scale. When implementing a DRP direction to recompute margins from annual reports, the TPO must remain within that direction and cannot exclude expenses as non-operating without a corresponding direction; margins require recomputation without those exclusions. High-turnover companies may be excluded where turnover disparity makes them unsuitable comparables for captive software-development services. Companies providing diversified, high-end technology, product-development, artificial intelligence, cloud, blockchain and specialised services are not functionally comparable with routine captive software-development and testing services. The arm's-length price requires redetermination after applying these comparability filters. en-us Tue, 17 Jun 2025 00:00:00 +0530 Sat, 31 Oct 2026 17:44:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=473022 Transfer-pricing benchmarking requires comparable companies to be functionally similar and reasonably comparable in scale. When implementing a DRP direction to recompute margins from annual reports, the TPO must remain within that direction and cannot exclude expenses as non-operating without a corresponding direction; margins require recomputation without those exclusions. High-turnover companies may be excluded where turnover disparity makes them unsuitable comparables for captive software-development services. Companies providing diversified, high-end technology, product-development, artificial intelligence, cloud, blockchain and specialised services are not functionally comparable with routine captive software-development and testing services. The arm's-length price requires redetermination after applying these comparability filters. Case-Laws Income Tax Tue, 17 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=473022