https://www.taxtmi.com/caselaws?id=472258 Transfer-pricing benchmarking of a captive, low-risk investment-advisory provider operating on a cost-plus basis must apply Rule 10B(2) functional comparability, including functions performed, assets employed and risks assumed. Companies engaged in stock-market operations, debt syndication, merchant banking, corporate finance, or fund-based/NBFC activities are unsuitable where they are functionally dissimilar, lack reliable segmental information, or fail consistently applied service-revenue and export-turnover filters. ICRA Management Consulting Services Pvt. Ltd. remains includible where functionally comparable; its margin falls within the statutory tolerance range, leaving no adverse arm's length price adjustment. en-us Mon, 11 Nov 2019 00:00:00 +0530 Tue, 06 Oct 2026 12:12:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472258 Transfer-pricing benchmarking of a captive, low-risk investment-advisory provider operating on a cost-plus basis must apply Rule 10B(2) functional comparability, including functions performed, assets employed and risks assumed. Companies engaged in stock-market operations, debt syndication, merchant banking, corporate finance, or fund-based/NBFC activities are unsuitable where they are functionally dissimilar, lack reliable segmental information, or fail consistently applied service-revenue and export-turnover filters. ICRA Management Consulting Services Pvt. Ltd. remains includible where functionally comparable; its margin falls within the statutory tolerance range, leaving no adverse arm's length price adjustment. Case-Laws Income Tax Mon, 11 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472258