https://www.taxtmi.com/caselaws?id=311859 ITAT Mumbai held that AISL should be excluded from comparables for transfer pricing adjustment. The taxpayer's Marketing Support Segment provided sales and marketing services to associated enterprises, while AISL offered professional consultancy services including customs, excise, and trade-related liaison services to multiple customers and traded in digital certificates. The tribunal found these functions were not comparable, as AISL's liaison services differed significantly from the taxpayer's dedicated marketing support services to AEs. The TPO erred in treating these distinct service profiles as comparable for benchmarking purposes. en-us Tue, 30 Aug 2022 00:00:00 +0530 Wed, 17 Jan 2024 21:07:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311859 ITAT Mumbai held that AISL should be excluded from comparables for transfer pricing adjustment. The taxpayer's Marketing Support Segment provided sales and marketing services to associated enterprises, while AISL offered professional consultancy services including customs, excise, and trade-related liaison services to multiple customers and traded in digital certificates. The tribunal found these functions were not comparable, as AISL's liaison services differed significantly from the taxpayer's dedicated marketing support services to AEs. The TPO erred in treating these distinct service profiles as comparable for benchmarking purposes. Case-Laws Income Tax Tue, 30 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311859