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2018 (2) TMI 1803 - AT - Income TaxTransfer pricing adjustment - rejection/selection of some of the comparables - functinal similarity - Held that:- The assessee an Indian company is engaged in the business of providing non-binding investment advisor services to its Associated Enterprise (A.E) General Atlantic Service Corporation, USA thus companies functionally dissimilar with that of assessee need to be deselected from final list. As AR has submitted before us that on inclusion of ICRA Management Consulting Services Ltd., IDC (India) Ltd. and exclusion of Ladderup Corporate Advisory Pvt. Ltd. and Motilal Oswal Investment Advisors Ltd., assessee's margin will fall within +/- 5% of the average margin of the remaining comparables. In view of the aforesaid submissions of the assessee, the issue relating to comparability of Crisil Rest and Infrastructure Solutions Ltd. being of mere academic nature is not required to be deliberated upon. Grounds raised by the assessee are partly allowed and ground raised by the Department is dismissed.
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