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it is noticed that this company has multiple segments, such as, outsourcing service, information service and software products & service. None of these segments are comparable to the non–binding investment advisory service provided by the assessee. Finding functional dissimilarity between this company and a simple advisory service provider the Tribunal in AGM India Advisors Pvt. Ltd. (supra), has held that this company cannot be a comparable to an investment advisory service provider. In fact, while considering the comparability of this company in assessee’s owncasefor the assessment year 2012–13, the Transfer Pricing Officer himself has categorically stated that none of the segments of ICRA Online Ltd. are comparable to investment advisory services rendered by the assessee and accordingly rejected it as a comparable. In our considered opinion, facts are not different in the impugned assessment year as well. That being thecase, we hold that this company cannot be treated as comparable to the assessee. Hence, should be excluded. 13. In course of hearing, it has been submitted before us by the learned Authorised Representative that on exclusion of these two companies, arithmetic mean of the rest of the comparables would work out to 26.57% and assessee’s margin shown at 23.16% would be within the acceptable range, requiring no further adjustment. Keeping in view the aforesaid submission, we do not intend to deliberate further on any other comparable at this stage and leave the issues relating to the comparability of the other comparables open for adjudication if they arise in assessee’scasein any other assessment year in future. The Assessing Officer is directed to determine the arm's length price of the international transaction with the AEs keeping in view our observations herein above. Grounds are partly allowed.

Shanti Prime Publication Pvt. Ltd.

Sec. 92, 92B, 92C of Income Tax Act, 1961—Transfer Pricing - The dispute in the present appeal hovers around the addition made of Rs. 3,23,85,404, on account of transfer pricing adjustment to the arm’s length price of the services provided to the Associated Enterprises (AE). The Tribunal while partly allowing the appeal o the assessee held that “we do not intend to deliberate further on any other comparable at this stage and leave the issues relating to the comparability of the other comparables open for adjudication if they arise in assessee’s case in any other assessment year in future. The AO is directed to determine the arm's length price of the international transaction with the AEs keeping in view our observations herein above”. - KHAZANAH INDIA ADVISORS PVT. LTD. V/s DEPUTY CIT - [2020] 184 ITD 890 (ITAT-MUMBAI)