TMI Blog2021 (12) TMI 315X X X X Extracts X X X X X X X X Extracts X X X X ..... facts and figures relating to comparable cases of other similarly placed entities, whose relevant data is available in the public domain. As per the provisions of the Act and the Rules, the assessee company is required to furnish its own Transfer Pricing Analysis and the list of chosen comparables which may or may not be agreed to by the Revenue Authorities and they would introduce some more comparables rejecting the comparables given by the assessee company by applying certain filters like Related Party Transactions (RPT) filter, turnover filter, export earnings filter, employee cost filter, etc. to bring them within the comparable range of the cases of such comparables and generally there would be a disagreement between the assessee a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... comparable companies by relying on the decisions of Carlyle India Advisors Pvt. Ltd. for A.Y. 2010-11 and Sparkles Dhando Advisors Pvt. Ltd. (ITAT/1047/M/2015-A.Y. 2010-11, dated 31.12.2015) without appreciating the facts, which brought on record that both the companies are providing advisory services and their activities similar to the activity of the assessee? 2. Whether for the purpose of establishing functional comparability of M/s. IDFC India Advisors Ltd. under Rule 10B(2), the Honourable ITAT was correct in concluding that the said company is not comparable to the assessee by relying on the decision in the case Carlyle India Advisors Pvt. Ltd. for A.Y. 2010-11 and Sparkles Dhando Advisors Pvt. Ltd. (ITA/1047/ M/2015 A.Y. 2010- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... laced entities, whose relevant data is available in the public domain. As per the provisions of the Act and the Rules, the assessee company is required to furnish its own Transfer Pricing Analysis and the list of chosen comparables which may or may not be agreed to by the Revenue Authorities and they would introduce some more comparables rejecting the comparables given by the assessee company by applying certain filters like Related Party Transactions (RPT) filter, turnover filter, export earnings filter, employee cost filter, etc. to bring them within the comparable range of the cases of such comparables and generally there would be a disagreement between the assessee and the revenue in such a situation. Therefore, the entire exercise of m ..... X X X X Extracts X X X X X X X X Extracts X X X X
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