https://www.taxtmi.com/caselaws?id=227254 The Court dismissed the appeal in a Transfer Pricing case concerning the determination of Arms Length Price (ALP) for investment advisory services. The Tribunal rejected eight additional comparables relied upon by the Transfer Pricing Officer (TPO), deeming them not functionally comparable with the respondent. Consequently, the Court upheld the respondent's ALP determination, as the difference in operating margins fell within the acceptable range. The Court declined to address the issue of a safe harbor margin, ultimately dismissing the appeal with no costs awarded. en-us Fri, 22 Feb 2013 00:00:00 +0530 Mon, 28 Oct 2013 12:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=227254 The Court dismissed the appeal in a Transfer Pricing case concerning the determination of Arms Length Price (ALP) for investment advisory services. The Tribunal rejected eight additional comparables relied upon by the Transfer Pricing Officer (TPO), deeming them not functionally comparable with the respondent. Consequently, the Court upheld the respondent's ALP determination, as the difference in operating margins fell within the acceptable range. The Court declined to address the issue of a safe harbor margin, ultimately dismissing the appeal with no costs awarded. Case-Laws Income Tax Fri, 22 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=227254