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| The Tax Publishers2019 TaxPub(DT) 2753 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
Though ICRA Management Consulting Services Ltd. had internally used the tools like (IMaCS Risk Scorers & IMaCS C-Cube Software) to render consulting and advisory Services, however, it did not earn any product income by using such tools, therefore, it could safely be taken as comparable in case of assessee providing non-binding investment advisory services.
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Transfer pricing - Determination of ALP - Selection of comparables -
Assessee rendered non-binding investment advisory services to its AE abroad. TPO consdiered. ICRA Management consulting services ltd. as non-comparable to assessee's case on the ground that ICRA Management Consulting Serviceds Ltd. had R&D functions and owned and developed intangible, i.e., IMACS Risk Scorer & IMACS C-Cube Software. Held: Though ICRA Management Consulting Services Ltd. had internally used the tools like (IMaCS Risk Scorers & IMaCS C-Cube Software) to render consulting and advisory Services, however, it did not earn any product income by using such tools, therefore, it could safely be taken as comparable in case of assessee providing non-binding investment advisory services.
Relied:Temasek Holdings Advisors (I) (P.) Ltd. v. ITO [ITA No. 1429 (Mum) of 2017, dt. 3-1-2018] : 2018 TaxPub(DT) 0416 (Mum-Trib).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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