PCIT v. Warburg Pincus India (P.) Ltd (2024) 296 Taxman 161 (Bom)(HC)

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Comparable-Functional similarity-Company engaged in marketing research and management activity was comparable to assessee-company, investment advisory services provider. [S. 260A]

Dismissing the appeal of the Revenue the Court held that the assessee-company was engaged in rendering investment advisory services. Selected company was engaged in market research and management activity. Since in some cases, said company was found to be comparable to investment advisory service provider, said company should be included as comparable. (AY. 2009-10)