TPG Capital India Pvt. Ltd. vs DCIT
Whether ICRA Management Consulting Services Ltd. is functionally comparable to the assessee for transfer pricing analysis --- Held Yes; Whether the margin of ICRA Management Consulting Services Ltd. should be computed at 16.26% instead of 29.48% --- Held Yes, subject to verification; Whether ICRA Online Pvt. Ltd. should be excluded as a comparable due to functional differences --- Held Remanded for fresh adjudication; Whether risk adjustment should be allowed for comparability analysis --- Held Yes, subject to verification; Whether Motilal Oswal Investment Advisors Pvt. Ltd. should be excluded as a comparable --- Held Yes.
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