https://www.taxtmi.com/caselaws?id=348538 The Delhi HC ruled on a transfer pricing case involving re-characterization of the assessee's function as a merchant banker. The assessee provided non-binding investment advisory services to its Associated Enterprise. The court held that the assessee's activities constituted fee-based investment/financial advisory services, distinguishing it from merchant bankers who engage in active financing transactions. Since the assessee only provided advisory services on financial matters rather than participating in actual financing, the court determined that companies functionally different from the assessee should be deselected from the final list of comparables for transfer pricing analysis. The decision emphasizes the importance of functional similarity when selecting comparables in transfer pricing determinations. en-us Mon, 18 Sep 2017 00:00:00 +0530 Mon, 21 Jul 2025 17:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=348538 The Delhi HC ruled on a transfer pricing case involving re-characterization of the assessee's function as a merchant banker. The assessee provided non-binding investment advisory services to its Associated Enterprise. The court held that the assessee's activities constituted fee-based investment/financial advisory services, distinguishing it from merchant bankers who engage in active financing transactions. Since the assessee only provided advisory services on financial matters rather than participating in actual financing, the court determined that companies functionally different from the assessee should be deselected from the final list of comparables for transfer pricing analysis. The decision emphasizes the importance of functional similarity when selecting comparables in transfer pricing determinations. Case-Laws Income Tax Mon, 18 Sep 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=348538