2018 (6) TMI 1756

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.... determination of arm's length price of the investment advisory services, the Tribunal has inadvertently not given any finding. Elaborating the same, our attention was invited to Ground of appeal no. 10 raised in the Memo of appeal, which reads as under:- "10. The learned DCIT/DRP erred in holding Motilal Oswal Investment Advisors Pvt. Ltd., Motilal Oswal Private Equity Advisors Pvt. Ltd. and Brescon Corporate Advisors Pvt. Ltd. as comparable to the Appellant." 3. It is pointed out that in para 7 of the order, Tribunal notes that apart from other concerns, M/s. Motilal Oswal Private Equity Advisors Pvt. Ltd. was also adopted as a comparable concern by the income-tax authorities. It is pointed out that by way of Ground of ap....

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....adly engaged in similar lines of business as the Appellant and which were selected by the Appellant in its transfer pricing study." 7. By referring to para 11 of the order of Tribunal dated 09.03.2016 (supra), the learned representative pointed out that the plea of the assessee was to include the following three concerns as comparables, namely, M/s. ICRA management Consultancy Services Ltd., M/s. ICRA Online Ltd. and M/s. IDC India Ltd. 8. The learned representative pointed out that whereas the Tribunal has determined the issue relating to inclusion of M/s. ICRA Management Consultancy Services Ltd., but the determination of inclusion of the other two concerns, namely, M/s. ICRA Online Ltd. and M/s. IDC India Ltd. in the final list of ....