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2018 (10) TMI 1640 - AT - Income TaxTPA - Comparable selection - functinal similarity - Held that:- The appellant is a captive service provider to its associated enterprises (AEs) and is primarily engaged in providing business development advisory and other support services to its AEs on a cost plus basis. Companies as government companies or Public Sector Undertakings therefore, should not be taken as comparable. Companies functionally dissimilar with that of assessee need to be deselected from final list. A company engaged in undertaking asset valuation, energy audits, revival studies, etc., and market assessment studies cannot be taken as comparable to assessee which is engaged as a business support and consulting service provider to its AEs who assumes minimal risk as it is compensated on a cost plus basis.
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