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2018 (6) TMI 1680 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Assessee is engaged in the business of providing non-binding investment advisory services to its associated enterprises i.e., to Saffron Capital Securities Limited, Mauritius. Assessee has benchmarked its international transaction under transactional Net Margin Method, thus companies functionaly dissimilar with that of assessee need to be deselected. Only if Motilal Oswal Investment Advisors Limited is rejected from the list of comparables selected by the TPO, the arithmetic name of PLI of the comparable will fall within +/- 5% range prescribed u/s. proviso to Section 92C of the Act, as applicable to A.Y.2010-11. Accordingly, there will be no transfer pricing adjustment.
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