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2016 (2) TMI 503 - AT - Income TaxTransfer pricing adjustment - selection of Motilal Oswal as comparable - Held that:- functions and activities carried out by Motilal Oswal are different from the functions and activities of the assessee company. Accordingly, the risk profiles of the two are also different. It has been clearly mentioned in the annual report of Motilal Oswal that the said company is engaged in the business of merchant banking and investment, business advisory services. We find that Motilal Oswal is not comparable to the assessee company and the AO is directed to exclude the same from the list of comparables and re-compute the Arm’s Length Price and also the Transfer Pricing Adjustment to be made, if any after the excluding the aforesaid company.
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