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2022 (12) TMI 861 - ITAT MUMBAITP Adjustment - comparable selection - selection of comparables for benchmarking the international transaction pertaining to “Provision of Investment Advisory Services" - HELD THAT:- Companies functionally dissimilar with that of assessee need to be deselected from final list. Transfer pricing adjustment - international transaction of “Payment of Interest on Fully Convertible Debentures (FCDs)" - HELD THAT:- As there is no change in facts and the methodology adopted by the assessee for benchmarking the international transaction of “Payment of Interest on FCDs‟ has been accepted in the prior years, we see no reason to deviate from the view so taken by the coordinate bench of Tribunal in assessee‟s own case cited supra. Further, the learned DR could not show us any reason to deviate from the aforesaid order. Thus, respectfully following the order passed by the coordinate bench of Tribunal in assessee‟s own case cited supra, we uphold the plea of the assessee and delete the impugned adjustment in respect of international transaction of “Payment of Interest on FCDs‟. Accordingly, grounds No. 1 and 2 aised in assessee's appeal are allowed.
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