TMI Blog2015 (1) TMI 1226X X X X Extracts X X X X X X X X Extracts X X X X ..... exclude M/s Motilal Oswal Investment Advisors Pvt. Ltd from the comparables and to recompute the adjustment to be made u/s.92C(1) & 92C of the Act. - ITA No. 1360/Mum/2014 - - - Dated:- 5-1-2015 - R. C. Sharma (Accountant Member) And Amit Shukla (Judicial Member) For the Petitioner : A. V. Sonde For the Respondent : S. D. Shrivastava ORDER R. C. Sharma (Accountant Member) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... LP. A perusal of three comparables considered by the TPO shows that M/s. Future Capital Investment Advisors Ltd., has operating profit at 21.79% whereas OPM of Motilal Oswal Investment Advisors Pvt Ltd is 72.33%. The comparables used by the TPO themselves are showing extreme OPM. A perusal of the Director‟s report of Motilal Oswal Investment Advisors Pvt Ltd shows that during the year under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nnot be considered as a comparable. We, accordingly, direct the AO not to consider Motilal Oswal Investment Advisors Pvt Ltd as a comparable for determination of ALP . Other decisions relied upon by the learned AR are as under :- i) Temasek Holdings Advisors (P) Ltd.(ITA No.4203/M/2012, dated 30-8-2013); and ii) Acumen Fund Advisory Services (I) Pvt. Ltd.(ITA No.143/M/14, dated 4-7- ..... X X X X Extracts X X X X X X X X Extracts X X X X
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