ITAT Mumbai Excludes MPS Ltd. as Comparable, Deletes ₹18.80 Crore TP Adjustment in ITES Case

Clarivate Analytics (India) Private Limited Vs Additional/JT/DY/ASSTT/CIT/ ITO (ITAT Mumbai) The ITAT Mumbai allowed the appeal of the assessee for AY 2018-19 and deleted the transfer pricing adjustment after directing exclusion of MPS Ltd. from the final set of comparables on the ground of functional dissimilarity. The assessee, engaged in providing Information Technology Enabled Services (ITES) relating to content development and editing services to its associated enterprises, had benchmarked its international transactions using the TNMM method. It characterized itself as a limited-risk capt...