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2015 (11) TMI 1713 - ITAT MUMBAITPA - determination of arm's length price of the international transaction of Provision of investment advisory related support services by the assessee company to its associated enterprise abroad - selection of comparable - Held that:- The appellant company belongs to the world-wide Carlyle group, which is primarily engaged in originating/structuring and acting as lend equity investor in management lead buyouts, strategic equity investments, equity private placements etc. and is primarily engaged in the business of managing investments of high net worth individuals/institutional investors. The Carlyle Group has also several individual funds and it is operating in more than 19 countries. Carlyle Hong Kong, which is the holding company of the captioned assessee, provides consulting services including investment advisory, technology support, management consultancy and other advisory services to the Carlyle Group concerns who are engaged in operating and managing of funds in the Asia Pacific region. The appellant-company, which is operating in India since 2000 as a subsidiary of Carlyle Hong Kong, provides Investment advisory related support services to Carlyle Honk Kong. Thus companies functionally dissimilar with that of assessee need to be rejected from final list.
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