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TMI Blog2018 (6) TMI 1680X X X X Extracts X X X X X X X X Extracts X X X X ..... e comparable will fall within +/- 5% range prescribed u/s. proviso to Section 92C of the Act, as applicable to A.Y.2010-11. Accordingly, there will be no transfer pricing adjustment. - ITA No.4060/Mum/2016 - - - Dated:- 20-6-2018 - Shri R.C.Sharma, AM And Shri Ram Lal Negi, JM Assessee by Shri Gopal Bohra Revenue by Shri V. Jenardhanan ORDER R.C.Sharma (A.M): This is an appeal filed by the assessee against the order of CIT(A)-56, Mumbai dated 22/03/2016 for A.Y.2010-11 in the matter of order passed u/s.143(3) r.w.s.144C of the IT Act. 2. Rival contentions have been heard and record perused. 3. Assessee is engaged in the business of providing non-binding i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Khshitij Investment Advisory Co Limited 32.33% 6 Motilal Oswal Investment Advisors Limited 97.87% Arithmetic Mean 42.51% 5. By the impugned order CIT(A) confirmed the action of the AO. Against which assessee is in further appeal before us. 6. It was argued by learned AR that if both the comparable selected by assessee is accepted as comparable and Motilal Oswal Investment Advisors Limited as selected by the TPO is rejected, there will be no transfer pricing adjustment as PLI of the assessee would remain at 25.34% which is higher than th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ate Limited -..(70 taxmann.com 219 AY 201011) at 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/2Q16 order dated 21.02.2018). Refer Internal page 11 12 respectively. Bombay HC in the case of General Atlantic Pvt. Ltd., (68 taxmann.com 88 refer internal page no. 1 to 3) 10. We also found that Motilal Oswal Investment Advisors Limited is a company engaged in the business of investment banking / merchant banking activity, hence not comp ..... X X X X Extracts X X X X X X X X Extracts X X X X
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