Dismissing the appeal of the Revenue the Court held that An investment advisor or sub-advisory cannot be compared with a merchant banker or investment banker. Followed CIT v. Carlyle India Advisors (P) Ltd (2013) 357 ITR 584 (Bom)(HC) (AY.2009-10)
PCIT v. Warburg Pincus India Pvt. Ltd. (2022) 449 ITR 329 / 329 CTR 933 / 219 DTR 361 //(2023) 290 Taxman 80 (Bom.)(HC)
S. 92C : Transfer pricing-Arm’s length price-Selection of comparables-An investment advisor or sub-advisory cannot be compared with a merchant banker or investment banker-Tribunal’s finding based on decision of Supreme Court-No question of law. [S. 260A]