Transfer pricing comparability requires turnover and functional analysis, alongside rules on exempt-income disallowance and amalgamation goodwill depreciation.

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....Direct expenses should be attributed to the relevant segment, while common expenses may be allocated by segment revenue; segmental results require examination before rejection. For the software development and ITeS segments, a Rs. 200 crore upper turnover filter reflects differences in functions, assets and risks; knowledge-intensive services are not comparable to routine ITeS. Foreign-currency receivables were benchmarked at LIBOR plus 200 basis points, with a 30-day credit period. No section 14A disallowance arose without exempt income for the relevant year; the Finance Act 2022 amendment operates prospectively from assessment year 2022-23. Consultancy fees for integrating related companies' operations were not accepted as business expend.........