Tribunal held that, company was mainly providing Asset management services and therefore, same could not be considered as comparable with market support services rendered by assessee.AO was directed to exclude such company from comparable. (AY.2010-11)
Philip Morris Services India S.A. v. ACIT (2018) 172 DTR 192 / 66 ITR 97 / (2019) 197 TTJ 128 (Delhi) (Trib.)
S. 92C : Transfer pricing—Comparables—Functionally indifferent companies cannot be selected as good comparable-Asset management company cannot be compared with market support services.