Transfer pricing adjustment in EPC firm's IPM segment: Issues with comparable selection based on profitability, functionality & FAR test.

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....Comparable selection for transfer pricing adjustment in the Information Process Management (IPM) segment was examined. UB Engineering Ltd. with negative operating margin of 46.58% was rejected as profitability is not a criteria, and future years' data was considered. Holtec Consulting Pvt. Ltd. and Neil Soft Ltd. were excluded as their functionality differed from the assessee, an Engineering, Procurement, and Construction (EPC) company. Info Edge India Ltd., an online search portal with substantially higher turnover, was rejected due to failing the Functional Asset Risk (FAR) test. The assessee's appeal was partly allowed, upholding certain comparables while rejecting others based on functional dissimilarities and FAR analysis.....