TMI Blog2013 (4) TMI 486X X X X Extracts X X X X X X X X Extracts X X X X ..... comparables are not proper and failure of the assessing officer to consider the objections of the assessee - In this view of the matter, we see no reason to entertain the Appeal. Whether Tribunal was correct in allowing safe harbor margin of (+/-) to the assessee - Held that:- It becomes academic as if the eight comparables selected by the TPO are found not to be functionally comparable then ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the TPO were not functionally comparable while determining ALP ? (b) Whether on the facts and circumstances of the case, the Tribunal was correct in allowing safe harbor margin of (+/-) to the assessee ?" 2. The basic dispute in this case is the determination of Arms Length Price (ALP) in respect of investment advisory and related support services by the respondent - assessee to its Associ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt assessment years, assessing officer has found that the eight comparables selected by the TPO were not functionally comparable with the respondent for determining the ALP. Moreover, in the impugned order the Tribunal has in detail pointed out why the selected comparables are not proper and failure of the assessing officer to consider the objections of the assessee. In this view of the matter, we ..... X X X X Extracts X X X X X X X X Extracts X X X X
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