Transfer Pricing Appeal Dismissed Due to Functional Dissimilarity of Comparables

PCIT Vs TCK Advisers Pvt. Ltd. (Delhi High Court) The Delhi High Court dismissed the Revenue’s appeal filed under section 260A of the Income-tax Act, 1961, challenging the order of the Income Tax Appellate Tribunal dated 11 November 2019 for Assessment Year 2010–11. The dispute arose from transfer pricing adjustments proposed in respect of investment advisory services rendered by the assessee to its Associated Enterprise (AE), Trikona Advisors Mauritius Limited, under a consultancy agreement dated 1 April 2008. The assessee provided non-binding investment advisory services, primarily in th...