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2020 (9) TMI 1099 - AT - Income TaxTP Adjustment - comparable selection - functional dissimilarity - HELD THAT:- Assessee provided investment advisory services, in respect of listed Indian securities to its overseas AE. Investment Advisory Services refer to the support services provided by the Indian firms to the overseas fund managers in equity and general business research. Further, equity research relates to building and maintaining valuation models, ratio analysis, competitor analysis, comparable valuation method etc. Business research includes services, such as study and analysis of the industry of the target company, company profiles and study of the macroeconomic environment of the target country, thus companies functinally dissimilar with that of assessee need to be deselected from final list. ICRA Management Consulting Services Ltd. (‘IMCSL’), Informed Technologies India Ltd. (‘ITIL’), IDC (India) Ltd., Ladderup Corporate Advisory Pvt. Ltd. to be included as valid comparable and direct the TPO/AO to exclude Ladderup Corporate Advisory Pvt. Ltd. from the list of comparables. M/s. Motilal Ostwal Investment Pvt. Ltd ('MOAIPL’) is to excluded as it is engaged in diversified activities and that segmental reporting is not available. New Berry Advisors Ltd. (‘NBAL’) is engaged in the business of marketing and distribution of financial products. Further, the notes to the financial statement mention that the company is in the business of distribution/marketing of financial products under the head ‘Inventories’, thus to be rejected.
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