Case Law Details
PCIT Vs Chrys Capital Investment Advisors (India) Pvt. Ltd. (Delhi High Court)
Introduction: In a recent development, the Delhi High Court has upheld the decision of the Income Tax Appellate Tribunal (ITAT) in the case of PCIT vs Chrys Capital Investment Advisors (India) Pvt. Ltd. The appeal, brought under Section 260A of the Income Tax Act, challenged the ITAT’s order, which partly allowed the appeal of the respondent/assessee. The primary contention revolved around the selection of comparables for determining the Arm’s Length Price (ALP) of an international transaction. Let’s delve into a detailed analysis of the case.
Background: Chrys Capital Investment Advisors, engaged in providing investment advisory services to its overseas Associated Enterprise (AE), faced scrutiny over the benchmarking of its transactions with the AE. The Transfer Pricing Officer (TPO) contested the initial benchmarking, asserting inappropriate filters and the exclusion of functionally similar comparables.
TPO’s Intervention:
1. The TPO independently selected comparables, resulting in an upward adjustment to the ALP.
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