Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental data.

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....Under TNMM, comparables for an assessee providing ITeS support services to its associated enterprise must be functionally similar and capable of reliable comparison. Tata Elxsi was unsuitable because its design and engineering, digital-content, R&D and software-development activities involved substantial intangibles. TTEC India Customer Solutions was unsuitable because its BPO, technology and AI-enhanced offerings differed from the tested ITeS support services. CHEERS was unsuitable because its mixed ITeS and other operations lacked segmental information. All three were excluded from the final comparable set; the issue of the assessee's unaudited segmental information remained open.....