Transfer pricing comparables in market research services turn on functional similarity and DRP-compliance remand issues.

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....Transfer pricing comparables for basic market research and testing services turned on functional comparability and related party screening. India Tourism Development Corporation Ltd. was retained as a comparable, while Unimed Diagnostics Private Limited, Medall Healthcare Private Limited, IGT Solutions Private Limited and Fuzen Software Private Limited were treated as functionally dissimilar because their business models differed from information-gathering and data-compilation services. The note also records that depreciation on computer software and disallowance of international travel expenses were sent back for fresh verification because the DRP directions had not been properly implemented.....