“working capital adjustment”

Transfer PricingSection 92CSection 92C508 judgments

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, BENGALURU vs. ANALOG DEVICES INDIA PRIVATE LIMITED, BENGALURU

In the result, the Cross Objection is dismissed as infructuous

ITA 2074/BANG/2024[2011-12]Status: DisposedITAT Bangalore12 Mar 2026AY 2011-12

Sasken Communication Technology Ltd\n13. Tata Elxsi Ltd\n\n5.3\nThe average PLI/margin of the comparables companies was\ncomputed after providing working capital adjustment, at 21.56%.\nAccordingly, an upward TP adjustment was made by the TPO for Rs.\n6,62,30,979/- only to the total income of the assessee

DY.COMMISSIONER OF INCOME TAX, MUMBAI vs. BP INDIA PVT LTD, MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 4907/MUM/2025[2011-12]Status: DisposedITAT Mumbai10 Mar 2026AY 2011-12

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2011-12 Deputy Commissioner Of Bp India Pvt. Ltd. Income Tax , Circle-1(2)(1), P B No 19411, Mumbai Vs. Technopolis Knowledge Park, Andheri, Mumbai - 400043 (Pan: Aaccb2030Q) (Appellant) (Respondent) C.O. No. 276/Mum/2025 Assessment Year: 2011-12 Bp India Pvt. Ltd. Deputy Commissioner Of Income P B No 19411, Tax , Circle-1(2)(1), Technopolis Knowledge Park, Vs. Mumbai Andheri, Mumbai - 400043 (Pan: Aaccb2030Q) (Appellant) (Respondent) Present For: Assessee : Ms. Chandni Shah, Mr. Amol Mahajan & Ms. Nidhi Agarwal, Cas Revenue : Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing : 18.12.2025 Date Of Pronouncement : 10.03.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue & Cross Objection Filed By The Assessee Against The Order Of Cit (A) 55, Mumbai, Vide Order No. Itba/Apl/S/250/2025-26/1076574916(1), Dated 30/05/2025, Passed Against The Assessment Order By Acit - 9(2)(1), Mumbai, U/S. 143(3) R.W.S 144(C)(3)(B) Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 13.04.2015, For Assessment Year 2011-12. 2

For Appellant: Ms. Chandni Shah, Mr. Amol Mahajan and Ms. Nidhi Agarwal, CAsFor Respondent: Shri Bhagirath Ramawat, Sr. DR

Section 143(3)

Rules, 1962 ('the Rules'). 3 ITA No. 4907/Mum/2025 and CO No.276/Mum/2025 BP India Pvt. Ltd. AY 2011-12 1.6. not allowing the working capital adjustment to eliminate the differences on account of varying working capital position between the assessee and the comparable companies, and 1.7. not allowing the risk adjustment

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

ITA 1842/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

Section 250

disputed that the assessee had benchmarked its international transactions of export of finished goods to AEs under the TNMM, and that working capital adjustment had been undertaken while computing the Profit Level Indicator (PLI). The assessee contended that the receivables are incidental and intrinsically linked to the primary international transaction ... sale of goods. The assessee also stated that the working capital adjustment duly captures the impact of credit terms, and therefore, a separate adjustment on outstanding receivables would lead to double taxation and the assessee maintained a uniform policy of not charging interest on delayed payments from both

PARAMETRIC TECHNOLOGY (INDIA) PRIVATE LIMITED,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(2), BENGALURU

In the result, the appeal of the assessee is partly allowed

ITA 2514/BANG/2024[2021-22]Status: DisposedITAT Bangalore24 Feb 2026AY 2021-22

For Appellant: Shri Darpan Kirpalani, CAFor Respondent: Dr. Divya K.J, CIT (DR)

Section 143(3)

include\ninterest, which is neither due nor collected.\n16.3 Further, the assessee contended that amount of outstanding\nreceivables gets adjusted in the working capital adjustments and hence,\naddition is not required separately thereon.\n16.4 Without prejudice to the above contentions, the assessee further\nsubmitted that the average realization period ... plethora of\njudicial courts in this regard.\n17.1 With regard to contention of assessee that interest on delayed\nreceivables gets adjusted within working capital adjustment and a\nseparate adjustment is not required, the Ld. DRP submitted that working\ncapital adjustment have no impact on determination of ALP on interest\nreceivables

M/S. NTT DATA GLOBAL SERVICES PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 5, BANGALORE

ITA 2533/BANG/2019[2015-16]Status: DisposedITAT Bangalore23 Feb 2026AY 2015-16

Section 133(6)Section 143(3)Section 144C(13)Section 144C(5)

benchmarking the SWD Segment. The arm's-length range\ndetermined by the Assessee-Company in its Transfer Pricing Study\nReport (TPSR) [after working capital adjustment], on the basis of 14\ncomparables selected by it, was 6.24% (35th percentile) to 20.31%\n(65th percentile), with a median of 14.52%.\nThe TNMM ... n2014-15 (wherever available) at the time of complying with\nthe transfer pricing documentation requirements.\n(c) A working capital adjustment ie, adjustment resulting from\nthe different levels of working capital accounts receivable,\ninventory and accounts payable between the\nAssessee/tested party and the comparable companies was\nperformed.\n(d) Since

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(1), VISAKHAPATNAM

ITA 533/VIZ/2024[2021-22]Status: DisposedITAT Visakhapatnam18 Feb 2026AY 2021-22

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 143(1)Section 143(3)Section 144C(1)Section 92C

such notional interest cost. The Ld. AR submitted that the Tribunal had, based on its aforesaid observations, directed the TPO to consider the working capital adjustment and its impact on the profits of the assessee vis-à-vis its comparables. The Ld. AR submitted that the Tribunal, based ... international transaction……….” Consistently following the above decision this ground No 8.1 raised by the assessee is dismissed 23. The assessee also submitted that working capital adjustment was rejected by the Ld. TPO. Further, we find that the dispute is with respect to selection of comparables and not with respect

BA CONTINUUM INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

ITA 368/HYD/2024[2005-06]Status: DisposedITAT Hyderabad04 Feb 2026AY 2005-06

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 10ASection 142(1)Section 143(2)Section 147Section 40

risk differences in accordance with the provisions of rule 10B(1)(e) of the Rules and not providing for the below adjustments; a) Working capital adjustment b) Risk adjustment 5 BA Continuum India Private Limited vs. DCIT c) Marketing and R&D expenditure adjustment d) Depreciation adjustment 14. Without prejudice

FIBERHOME INDIA (P) LTD,NEW DELHI vs. ACIT, CIRCLE-7(1), NEW DELHI

Appeal of the assessee is partly allowed

ITA 6083/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Jan 2026AY 2021-22

Bench: Ms. Madhumita Roy & Shri Manish Agarwalassessment Year: 2021-22

Section 14Section 143(3)Section 144BSection 144C(5)Section 92C

manufacturing of telecommunication equipment. 2.5 That the learned AO/TPO/DRP have also erred both in law and on facts in not making the working capital adjustment in the margin of comparable companies concerning international transactions related to the 3 import of goods for the manufacturing of telecommunication equipment, despite the working ... appeal before us. 3.8 It is the case of the assessee that the Ld. TPO has grossly erred in not allowing working Capital Adjustment to the PLI for appellant and the comparables even after the same ahs been allowed the Ld. DRP in their following directions dated 30.09.2024: “16.4 Accordingly

GE INDIA EXPORTS PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 293/BANG/2016[2011-12]Status: DisposedITAT Bangalore27 Jan 2026AY 2011-12

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sachit Jolly, Sr. Advocate & Ms. ViyushtiFor Respondent: Dr. KJ Divya, CIT (DR)

Section 143(3)Section 144C(5)Section 254

Infosys Ltd 13. Persistent Systems & Solutions Ltd 11. The average PLI/margin of the comparable companies computed at 24.82% and after providing working capital adjustment, the adjusted margin of the comparables arrived at 23.76% by the TPO. Accordingly, IT(TP)A No.253 & 293/Bang/2016 Page 6 of 28 an upward TP adjustment ... appeal of the revenue is hereby dismissed. 26. The next issue raised by the assessee through Ground No. 7 and 9 pertaining to working capital adjustment, risk adjustment. 26.1 At the outset, we note the learned AR before us submitted that the assessee is not willing to press this issue

DCIT, BANGALORE vs. M/S GE INDIA EXPORT PVT. LTD.,, BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 253/BANG/2016[2011-12]Status: DisposedITAT Bangalore27 Jan 2026AY 2011-12

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sachit Jolly, Sr. Advocate & Ms. ViyushtiFor Respondent: Dr. KJ Divya, CIT (DR)

Section 143(3)Section 144C(5)Section 254

ARIBA INDIA PRIVATE LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, DELHI

In the result, appeal of the assessee is allowed

ITA 2705/DEL/2024[2011-12]Status: DisposedITAT Delhi27 Jan 2026AY 2011-12

Bench: SHRI YOGESH KUMAR U.S (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 144CSection 144C(13)Section 144C(3)Section 92CSection 92C(3)

separate notional addition of alleged interest on accounts receivables despite the fact that the same has already been counted by way of working capital adjustment on the comparables. Corporate Tax 5. That on the facts and in the circumstances of the case and in law, the AO / DRP erred

LOCKHEED MARTIN INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal of the assessee is partly allowed and the

ITA 960/DEL/2016[2011-12]Status: DisposedITAT Delhi23 Jan 2026AY 2011-12

Bench: Shrivikas Awasthy & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.960/Del/2016 िनधा"रणवष"/Assessment Year: 2011-12 बनाम Lockheed Martin India Pvt. Ltd., Act, The Grand Plaza, The Grand Hotel, Vs. Circle 15(2), Nelson Mandela Marg, C.R. Building, Vasant Kunj, Phase-1, New Delhi. New Delhi. Pan No.Aabcl4556E अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 144C

Revised addition 1,04,84,439 It is seen that one of the directions of the Ld. DRP for providing working capital adjustment was not considered by the TPO in arriving at the impugned upward revision. The assessee is aggrieved with this action and has approached the ITAT with ... during the Financial Year 2010-11. 6. The Ld. TPO, Ld. AO and the Hon'ble DRP have erred in not making a working capital adjustment and other appropriate adjustments on account of differences in the risk profile of the appellant vis-a-vis the comparables, while computing

RED HAT INDIA PRIVATE LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX , CIRCLE 15(3)(1), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 3853/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Jan 2026AY 2016-17

Section 143(3)Section 154Section 254Section 92C

1379/Mum/2021, partly allowed the appeal. While adjudicating the matter, the Tribunal specifically held that the assessee was entitled to working capital adjustment and proportionate adjustment, and accordingly restored the matter to the file of the TPO with clear and categorical directions to verify the computations furnished by the assessee ... transfer pricing study and detailed working capital adjusted margin computation, and thereafter grant appropriate adjustment in accordance with settled judicial principles. The directions issued by the Tribunal were neither tentative nor discretionary, but binding in nature. 7. Pursuant to the aforesaid directions, the learned TPO initiated remand proceedings and passed

TE CONNECTIVITY INDIA PRIVATE LIMITED,BANGALORE vs. THE OFFICE OF THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 7(1)(1), BANGALORE

In the result, the appeal of the assessee is hereby partly allowed

ITA 1789/BANG/2024[2020-21]Status: DisposedITAT Bangalore08 Jan 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Darpan Kriplani, CAFor Respondent: Dr. KJ Dhivya, CIT (DR)

profit of the tested party is equal or above the profit of comparables, even after taking into account the effect of working capital adjustment and the ALP is less than the price charged by the tested party, it cannot be said that the extra credit allowed is not an independent

ERM INDIA PRIVATE LIMITED,GURUGRAM vs. ASSESSMENT UNIT (JAO- DCIT, CIRCLE 7(1), DELHI), DELHI

In the result, this appeal is partly allowed

ITA 5459/DEL/2024[2021-22]Status: DisposedITAT Delhi07 Jan 2026AY 2021-22

Bench: Shriyogesh Kumar Us & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.5459/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Erm India Private Limited, Assessment Unit, 3Rd Floor, Tower B, Building No.10, Vs. Income Tax Department, Dlf Cyber City, Phase-Ii, (Jurisdictional Ao: Deputy Gurugram, Haryana. Commissioner Of Income-Tax), Pan No.Aaace1502C Circle 7(1), Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 144C(13)Section 253(1)(d)Section 92B

submitted to demonstrate that higher margins were earned by the Appellant and vis-a-vis third-party comparable companies even after undertaking the working capital adjustment. 2.5. That on the facts and circumstances of the case and in law, the AO/TPO/DRP erred in ignoring the fact that ... Income-tax Appellate Tribunal in assessee's own case in ITA No 513/Del/2021, with same fact pattern, has held that working capital adjustment subsumes the impact of interest on receivables and as such no separate benchmark for it has to be made. 2.6. That on the facts and circumstances

GIESECKE AND DEVRIENT INDIA PVT LTD.,GURGAON vs. ACIT (OSD), NEW DELHI

In the result, assessee’s appeal in ITA No

ITA 1428/DEL/2022[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Ms. Madhumita Roy & Smt. Renu Jauhriassessment Year: 2018-19

Section 119Section 143(3)Section 144BSection 144B(8)Section 144C(13)Section 144C(5)

read with Rule 10B(3) of the Rules. 17. That the TPO/DRP erred in not appreciating that risk and working capital adjustment had consistently been granted to the Appellant in the preceding years and in the absence of any change in facts, ought to have been allowed to the Appellant ... LIBOR rate is to applied in calculating the interest on receivables. 39. That without prejudice, the TPO/AO erred not appreciating that once the working capital adjustment was taken into account, as had been allowed to the Appellant in there preceding years, no separate adjustment on account of receivables was warranted

DY COMMISSIONER OF INCOME TAX, MUMBAI vs. BP INDIA PVT LTD, MUMBAI

In the result, the grounds of appeal raised by Revenue are

ITA 4873/MUM/2025[2012-13]Status: DisposedITAT Mumbai31 Dec 2025AY 2012-13

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2012-13 (Physical Hearing) Dy. Commissioner Of Income Tax, Bp India Pvt. Ltd. Room No.535, Aayakar Bhavan, Pb No. 19411, Technopolis Vs. Mumbai – 400020. Knowledge Park, Andheri, Mumbai- 400043. Pan No. – Aaccb2020Q (Appellant) (Respondent) C.O. No. 277/M/2025 In Ita No.4873/M/2025 Assessment Year: 2012-13

For Appellant: Ms. Chandni Shah/ Mr. AmolFor Respondent: Shri Bhagirath Ramawat (SR. D.R.)

Section 234DSection 271(1)(c)

provisions of Rules 10B(2) and (3) read with Rule 10C of the Income-tax Rules, 1962 (the Rules") 1.6. not allowing the working capital adjustment to eliminate the differences on account of varying working capital position between the Assessee and the comparable companies, and 1.7. not allowing the risk ... challenged the inclusion of Excel Infoways Limited and not including Jindal Intellicom Ltd. in final set of comparable as well as not allowing working capital adjustment and risk adjustment by TPO. 7. The Ld. CIT (A) after considering the order of TPO, submission of Assessee and the material placed before

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE vs. MS ZYME SOLUTION PRIVATE LIMITED, BANGALORE

Accordingly the appeal of the ld. AO and the CO of the assessee are partly allowed,

ITA 1885/BANG/2024[2013-14]Status: DisposedITAT Bangalore19 Dec 2025AY 2013-14

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2013-14

For Appellant: Shri Narendra Jain, AdvocateFor Respondent: Shri N. Balusamy, Jt.CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 92C

TPSR) computed the margins of the assessee at 10.01% and set of comparable companies margin was determined at 2.73% on Operating Cost without working capital adjustment. Assessee submits that it is at arm’s length. 5. The ld. TPO examined the TPSR wherein after examination same was rejected

NTT DATA GLOBAL DELIVERY SERVICES PVT LTD,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-5(1)(1), BANGALORE

In the result appeal of the assessee is partly allowed for statistical purposes

ITA 2062/BANG/2017[2013-14]Status: DisposedITAT Bangalore18 Dec 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Chavali Narayan, CAFor Respondent: Dr. Divya K.J – CIT

adjudicating the same. 38. The revised ground No. 21 of the assessee’s appeal is that the AO/DRP erred in not providing the working capital adjustment even though the TPO has accepted the same. 38.1 At the outset the ld. DR requested to issue a direction to allow the adjustment ... working capital adjustment as per the provisions of law. On the contrary, the ld. DR raised no objection on issuing such a direction. Accordingly, we direct the TPO to provide the necessary adjustment qua the working capital after necessary verification and as per law. Hence, the ground of appeal

NTT DATA GLOBAL DELIVERY SERVICES PVT LTD,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1)(1), BANGALORE

In the result appeal of the assessee is partly allowed for statistical purposes

ITA 1720/BANG/2017[2013-14]Status: DisposedITAT Bangalore18 Dec 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Chavali Narayan, CAFor Respondent: Dr. Divya K.J – CIT

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