Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pricing.

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....Transfer-pricing comparability for software development services requires selection of companies that meet applicable functional filters and have sufficiently comparable operations. Prior acceptance of a comparable before the Transfer Pricing Officer does not prevent an assessee from contesting it before the DRP. Diversified software-service and product companies lacking segmental information, or earning product-related income through outsourced product development, may be excluded as functionally dissimilar. Brand value and scale may materially affect comparability, supporting exclusion of a large branded company; an onsite filter may also be applied where appropriate. For accurate arm's-length price determination, the DRP may entertain objections, apply a new lawful filter, and direct inclusion or exclusion of comparables.....