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2019 (9) TMI 1599 - AT - Income TaxTP Adjustment - comparable selection - adjustment on provision for Research and Information Transaction is exclusion of the company M/s Aditya Birla Capital Advisor P. Ltd from set of comparables - HELD THAT:- It is undisputed that the company M/s Aditya Birla Capital Advisors Pvt. Ltd. has earned revenue from providing management services. Further, from the annual report of the company, it is also evident that the company has been engaged in advising and managing venture capital funds. The activity of advising investment management is quite distinct from the services provided by the assessee under the transaction of research and information services. We hold that the company is functionally dissimilar to the assessee and direct the learned AO/TPO to exclude the company from the final set of the comparables. TP adjustment - interest on outstanding receivables arising from International transactions of research and information and IT support services - HELD THAT:- Tribunal in the case of Pegasystems Worldwide India (P) Ltd [2015 (10) TMI 2495 - ITAT HYDERABAD] has held as in case of a debt free company, there is no requirement for making transfer pricing adjustment on account of the interest on outstanding receivables. We have verified the balance sheet of the assessee and find that the assessee has not borrowed any fund for its business activity and, thus, it being a debt free company, the ratio of the decision of the Tribunal in the case of Pegasystems Worldwide India (P) Ltd Vs ACIT (supra) is squarely applicable on the facts of the case. Accordingly, we delete the transfer pricing adjustment made on account of interest on receivables - Decided in favour of assessee.
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