No functional incomparability if TPO not reject a comparable on same ground

Investment Banking/ Merchant Banking activities held by the Tribunal as functionally different from provision of Investment Advisory services

The only comparable chosen by the assessee viz., M/S.IDC India Ltd., which has also been relied upon by the TPO now survives for consideration. The com parables chosen by the assessee on the basis of the contemporaneous data for A.Y 2006- 07 gives an arithmetic mean of 18.97% which we have already mentioned. This is the highest arithmetic

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