2018 (6) TMI 1680

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....tment advisory services to its associated enterprises i.e., to Saffron Capital Securities Limited, Mauritius. Assessee has benchmarked its international transaction under transactional Net Margin Method. Assessee has selected following companies as functionally comparable in its transfer pricing study report. 1. ICRA Management Consulting Services Ltd., 2. IDC (India) Limited 4. Assessee computed its operating profit to cost at 25.34% and of the comparable selected was 4.02% (average margin). Accordingly as per assessee, the international transaction was at an arm's length price. During the course of scrutiny assessment, AO referred the matter to the TPO who rejected the comparable selected by the assessee and has adopted following si....

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....nctionally comparable with the assessee's company. In the following judicial pronouncements it has been held to be eligible for comparison. * AGM India Advisors Pvt. Ltd., (70 taxmann.com 219 AY 2010-11 internal page no 14 & 15 * Tameasek Holding Advisors India Private Limited (ITA 776/M/2015 AY 2010-11) at internal page no 26 to 28 * Temasek Holdings Advisors India Private Limited (ITA: 4203/M/2012 & 6504/M/2012)at internal page no 57 & 58 * Mumbai ITAT in General Atlantic Pvt. Ltd. v DCIT (ITA 2207/M/2016 order dated 21.02.2018). Refer para 6 & 14 on page 4 & 10 respectively 9. Similarly, IDC (India) Limited is also engaged in advisory and consultancy services and functionally comparable with the assessee. In the following j....