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General Atlantic P. Ltd, Mumbai vs Dcit Cir 5(1)(1), Mumbai on 12 April, 2019 cites

Lr2 Management K/S Agent Of Principal ... vs The Income Tax Officer, (Inter. ... on 9 August, 2018

सत्म वऩत प्रतत //True Copy// आदे शानुसार/ BY ORDER, उि/सहायक िंजीकार (Dy./Asstt. Registrar) आयकर अिीऱीय अधिकरण, भुंफई / ITAT, Mumbai P a g e | 11 ITA No. 900/Mum/2017 AY. 2012-13 General Atlantic Private Ltd. Vs. Deputy Commissioner of Income Tax, Circle-5(1)(1)
Income Tax Appellate Tribunal - Rajkot Cites 25 - Cited by 7 - Full Document

Pr. Commissioner Of Income Tax-5 vs M/S. General Atlantic Pvt. Ltd on 12 March, 2019

The ld. A.R further took us through the observations of the Hon‟ble High Court of Bombay in the assesses own case for A.Y. 2006-07 i.e CIT-3, Mumbai Vs. General Atlantic (P) Ltd. (2016) 68 taxman.com 88 (Bom). It was submitted by the ld. A.R that the Hon‟ble High court had in its aforesaid order upheld the view taken by the Tribunal that the assessee was functionally similar to M/s Carlyle India which was providing non- binding investment advisory services to its AE. In sum and substance, it was the contention of the ld. A.R that the assessee was providing non-binding investment advisory services to its AE i.e General Atlantic Service Corporation, USA, which fact had been approved by the Hon‟ble High Court in its aforementioned case for the preceding year. It was averred by the ld. A.R that there was no change in the functional profile of the assessee during the year under consideration and it continued to render non-binding investment advisory services to its aforementioned AE. In fact, it was submitted by the ld. A.R that the Tribunal while disposing off the cross-appeals in the assesses own case for A.Y. 2011-12, had observed that undisputedly the assessee was engaged in the business of providing non-binding investment advisory services to its AE viz. General Atlantic Service Corporation, USA. In the backdrop of the aforesaid fact that the assessee was a non-binding investment advisory service provider, it was submitted by the ld. A.R that the AO/TPO had erred in including Ladderup Corporate Advisory Pvt. Ltd. as a comparable for benchmarking the international transactions of the assessee.
Bombay High Court Cites 1 - Cited by 7 - S V Kotwal - Full Document

Temasek Holdings Advisors India P.Ltd, vs Dcit 14(3)(1), on 16 May, 2017

Apart there from, it was submitted by the ld. A.R that the Tribunal while disposing off the aforesaid appeal had also relied on the order passed in the case of Temasek Holdings Advisors India (P) Ltd. Vs. DCIT (2017) 87 taxman.com 168 (Mum), in which case the Tribunal had after necessary deliberations concluded that as Ladderup Corporate Advisory Pvt. ltd. which was engaged in merchant banking/investment banking and other similar activities during the year was functionally incomparable to the assessee before them which was providing non- binding investment advisory services, hence it could not be included in the final list of comparables. The ld. A.R culminating his contentions submitted that as it stood proved to the hilt that Ladderup Corporate Advisory Pvt. Ltd. was functionally incomparable to the assessee, therefore, the same may be excluded from the final list of comparables.
Income Tax Appellate Tribunal - Mumbai Cites 0 - Cited by 25 - Full Document

Temasek Holdings Advisors India P.Ltd, ... vs Ito Cir 14(3)(1), Mumbai on 3 January, 2018

Before parting, we may herein observe that the Tribunal in the case of Temasek Holding Advisors Pvt. Ltd. Vs. ITO, Circle 14(3)(1), Mumbai (ITA No. 1429/Mum/2017; dated 03.01.2018 for A.Y. 2012-13) had after necessary deliberations rejected the aforementioned company i.e Ladderup Corporate Advisory Services Pvt. Ltd. as a comparable in the case of the assessee before them which was providing non-binding investment advisory services.
Income Tax Appellate Tribunal - Mumbai Cites 13 - Cited by 2 - Full Document

Caryle India Advisors P.Ltd, Mumbai vs Ito 14(1)(2), Mumbai on 27 February, 2019

Further, the Hon‟ble High Court of Delhi in the case of Avenue Asia Advisors Pvt. ltd .Vs. DCIT (2017) 85 taxman.com 311 (Del) had also rejected Ladderup Corporate Advisory Pvt. Ltd. as a comparable in the case of an assessee which was providing non-binding investment services to its AE. In fact, this Tribunal had recently while disposing off the appeal in the case of Carlyle India Advisors Pvt. Ltd. Vs. ITO, 14(1)(2), Mumbai (ITA No. 2366/Mum/2017) for A.Y. 2012-13, had directed the A.O/TPO to exclude the aforementioned company i.e Ladderup Corporate Advisory Pvt. Ltd. from the final list of the comparables for computing the ALP of the international transactions of the assessee which was providing non-binding investment services to its AE. In sum and substance, as the aforementioned company viz. Ladderup Corporate Advisory Pvt. Ltd. is functionally different as in comparison to the assessee before us, therefore, as observed by us hereinabove, the A.O/TPO are directed to exclude the aforementioned company viz.
Income Tax Appellate Tribunal - Mumbai Cites 36 - Cited by 1 - Full Document
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