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2024 (1) TMI 841 - AT - Income TaxTP Adjustment - comparable selection for determining ALP in respect of Marketing Support Services - HELD THAT:- Axis Integrated System Ltd. - As per the marketing support services agreement the assessee was engaged in providing services to its associate enterprise regarding the marketing of product whereas the Axis Integrated System Ltd. was engaged in providing services related to Directorate General of Foreign Trading, customers/ excise and tax related services which were in the nature of professional consultancy services. Similarly, in the case of the assessee itself for A.Y. 2014-15 [2023 (8) TMI 1420 - ITAT MUMBAI] after following the above referred decision directed the AO/TPO to exclude the Axis Integrated System Ltd. as comparable. Following the decision of the ITAT as referred supra the AO is directed to exclude the AISL from the list of the comparable, therefore, ground of appeal no. 1.6 to 1.8 are allowed. Killick Agency and Marketing Ltd. be excluded considering the different function and revenue and activity. Majestic Research and Solution Ltd. was engaged in various activity like study, design, data collection etc. and the function was not comparable with the assessee company, thus we direct the assessing officer to exclude this company from the list of comparable.
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