TPG Capital India Pvt. Ltd. vs DCIT

Whether ICRA Management Consulting Services Ltd. is functionally comparable to an investment advisory service provider for transfer pricing analysis --- Held Yes; Whether the margin of ICRA Management Consulting Services Ltd. should be computed at 16.26% after proportionate allocation of unallocated expenditure --- Held Yes, subject to verification; Whether ICRA Online Pvt. Ltd. should be excluded as a comparable due to functional differences --- Held Matter restored to Assessing Officer for fresh adjudication; Whether risk adjustment should be allowed for comparability analysis under rule 10B(1)(e)(iii) --- Held Yes, in principle, subject to verification; Whether Motilal Oswal Investment Advisors Pvt. Ltd. is comparable to an investment advisory service provider --- Held No.