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| The Tax Publishers2020 TaxPub(DT) 3601 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
CRISIL engaged in providing niche advisory services in relation to financial markets and employing huge intangibles in order to achieve its targets was functionally not comparable to routine marketing support services provider like assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissilimarity and huge intangibles
Assessee rendered marketing support services to its AE abroad. TPO considered CRISIL as comparable to assessee's case.Held: CRISIL engaged in providing niche advisory services in relation to financial markets and employing huge intangibles in order to achieve its targets was functionally not comparable to routine marketing support services provider like assessee.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2004-05 & 2005-06
INCOME TAX ACT, 1961
Section 92C
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