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2020 (1) TMI 251 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Assessee is engaged in providing rating support services and other support services to its AEs. It functions as a risk mitigated contract service provider. Ladderup Corporate Advisory Private Limited should be excluded from the list of comparables on account of different functionality - A perusal of Schedule 11 of the Profit & Loss Account of Ladderup Corporate Advisory Private Limited shows that the main source of finance of the said comparable was by way of financial management and consultancy fees. We, therefore, find merit in the argument of the ld. Counsel for the assessee that the activities of this company was undoubtedly different from the activities of the assessee which was not into the business of financial and management consultancy fees Motilal Oswal Investment Advisors Private Limited - this company operates in four different business verticals. A perusal of the Director’s Report shows that the company derives its business income from four different business verticals viz., equity capital markets, mergers and acquisitions, private equity syndication and structured debt. no segmental data is available in the annual report. A perusal of the segment reporting shows that the company is engaged in single segment and there are no reportable business segment as per AS-17. We find the assessee company is engaged in providing high end rating support and would require skilled personnel in the field of merchant banking, actuary, financial advisory, etc. The functions performed by Motilal Oswal Investment Advisors Private Limited which is into merchant banking activities, in our opinion, cannot be compared to the functions of the assessee whose functions are strictly limited to that of providing rating support services.
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