PCIT v. AGM India Advisors P. Ltd. (2020) 275 Taxman 71 / (2021) 200 DTR 145 / 320 CTR 98(Bom.)(HC)

S. 92C : Transfer pricing-Arm’s length price-Comparable-Functionally similarity-Activities of merchant banker cannot be acceptable as comparable.

Dismissing the appeal of the revenue where assessee was engaged in rendering investment advisory services to AE, a company providing purely advisory services in various industries was acceptable as comparable and also a research company primarily dealing in research and survey services similar to that of assessee, could be accepted as comparable. (AY. 2011-12)