https://www.taxtmi.com/caselaws?id=311910 The Revenue challenged the exclusion of five comparables (Info Edge India Ltd., Media Research Users Council, MMTV Ltd., Power Systems Operation Corpn. Ltd., and TSR Darashaw) in a transfer pricing adjustment case before ITAT Delhi. The Tribunal dismissed the Revenue's appeal, holding that these comparables were functionally dissimilar to the assessee company. The assessee provided marketing support services to its Japanese parent and group companies, while the contested comparables had different functional profiles as evidenced by their annual reports. The DRP's direction to exclude these comparables was upheld, with the Revenue failing to demonstrate functional similarity between the comparables and the assessee. en-us Fri, 25 Jan 2019 00:00:00 +0530 Sat, 20 Jan 2024 21:00:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311910 The Revenue challenged the exclusion of five comparables (Info Edge India Ltd., Media Research Users Council, MMTV Ltd., Power Systems Operation Corpn. Ltd., and TSR Darashaw) in a transfer pricing adjustment case before ITAT Delhi. The Tribunal dismissed the Revenue's appeal, holding that these comparables were functionally dissimilar to the assessee company. The assessee provided marketing support services to its Japanese parent and group companies, while the contested comparables had different functional profiles as evidenced by their annual reports. The DRP's direction to exclude these comparables was upheld, with the Revenue failing to demonstrate functional similarity between the comparables and the assessee. Case-Laws Income Tax Fri, 25 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311910