https://www.taxtmi.com/caselaws?id=439706 APITCO Ltd. was not a valid comparable for transfer pricing benchmarking because it was functionally dissimilar to the assessee. The assessee provided project management, cost management and management consultancy services, while APITCO carried on a much wider mix of activities, including skill development, entrepreneurship development, training, research studies, asset reconstruction, energy-related services, tourism infrastructure development and environmental management. Its revenue profile was also materially different, with substantial receipts from government-oriented initiatives, and its ownership pattern differed significantly. On these facts, the entity lacked functional similarity and could not reliably be used as a comparable, so the exclusion was upheld and the assessee succeeded on the transfer pricing issue. en-us Wed, 28 Jun 2023 00:00:00 +0530 Fri, 30 Jun 2023 09:35:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439706 APITCO Ltd. was not a valid comparable for transfer pricing benchmarking because it was functionally dissimilar to the assessee. The assessee provided project management, cost management and management consultancy services, while APITCO carried on a much wider mix of activities, including skill development, entrepreneurship development, training, research studies, asset reconstruction, energy-related services, tourism infrastructure development and environmental management. Its revenue profile was also materially different, with substantial receipts from government-oriented initiatives, and its ownership pattern differed significantly. On these facts, the entity lacked functional similarity and could not reliably be used as a comparable, so the exclusion was upheld and the assessee succeeded on the transfer pricing issue. Case-Laws Income Tax Wed, 28 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439706