Transfer pricing comparability under TNMM refined: functional filters, aggregate RPT testing, and working capital adjustments controlled the outcome.

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....TNMM comparability must remain functionally robust: several software service comparables were excluded for lack of functional similarity, aggregate related-party transaction filtering was required for all selected comparables, and certain companies were restored for fresh FAR analysis or year-end data review. Working capital adjustment was restored because comparable margins must be adjusted for material profit-affecting differences; risk adjustment was refused for lack of demonstrated quantification, and delayed receivables were to be recomputed after giving effect to the final working capital adjustment. The mark-up on reimbursements was deleted for lack of factual and legal basis, interest income on the loan was remanded for fresh real-i.........