https://www.taxtmi.com/caselaws?id=444973 ITAT Mumbai upheld CIT-A's direction to include Cyber Media Research Ltd as comparable for transfer pricing, finding TPO's functional comparability rejection unfounded. Court dismissed AO's appeal on comparable selection. CIT-A's exclusion of IDFC Investment Advisors Ltd, Ledger Up Corporate Advisory Pvt Ltd, and Motilal Oswal Investment Advisors Pvt Ltd from comparables was upheld due to different business functions. Error trade loss disallowance was deleted following HC precedent. Section 14A disallowance was confirmed as AO recorded proper satisfaction. Ad hoc 10% disallowance on entertainment, repair, and books expenses was reversed for lack of specific instances. Kshitij Investment Advisory Co Ltd was excluded from comparability analysis due to business hive-off affecting profitability. en-us Wed, 25 Oct 2023 00:00:00 +0530 Fri, 27 Oct 2023 20:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444973 ITAT Mumbai upheld CIT-A's direction to include Cyber Media Research Ltd as comparable for transfer pricing, finding TPO's functional comparability rejection unfounded. Court dismissed AO's appeal on comparable selection. CIT-A's exclusion of IDFC Investment Advisors Ltd, Ledger Up Corporate Advisory Pvt Ltd, and Motilal Oswal Investment Advisors Pvt Ltd from comparables was upheld due to different business functions. Error trade loss disallowance was deleted following HC precedent. Section 14A disallowance was confirmed as AO recorded proper satisfaction. Ad hoc 10% disallowance on entertainment, repair, and books expenses was reversed for lack of specific instances. Kshitij Investment Advisory Co Ltd was excluded from comparability analysis due to business hive-off affecting profitability. Case-Laws Income Tax Wed, 25 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444973