Marketing & liasoning services can’t be equated with advisory services for ALP adjustment

Brief Facts 1. The assessee company is engaged in the business of providing investment advisory and marketing support services. The assessee company provided advisory services to its Associated Enterprises (“AEs”) named Deutsche Asset Management (Asia) Limited (in short “DAMAL”), Singapore. DAMAL is a fund Manager for Deutsche India Equity Fund. 2. In consideration for providing such advisory services, DAMAL has given 50% shares of the fees received by it to the assessee. The TPO noticed that the assessee has received share of 70% of the fees from another AE, Germany for providing liai...