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“working capital adjustment”

Transfer PricingSection 92CSection 92C508 judgments

The decision most relied on for working capital adjustment is Sony India (P) Ltd. v. DCIT (114 ITD 448), cited in 131 judgments on BharatTax.

Leading authorities on working capital adjustment

Sony India (P) Ltd. v. DCIT
114 ITD 448 · 2008 · ITAT
131
citing judgments

For transfer pricing purposes, functionally dissimilar entities that have significant business differences must be excluded from the list of comparables for benchmarking analysis. It also provides guidance on the non-allocation of advertisement, marketing, and promotion (AMP) expenses to other entities when incurred solely for the assessee's business.

Pr. CIT v. Kusum Health Care Pvt. Ltd.
398 ITR 66 · 2017 · High Court
100
citing judgments

Not every item of receivables appearing in the accounts of an entity dealing with foreign associated enterprises automatically constitutes an international transaction under Section 92B. A separate adjustment for interest on outstanding receivables is not permissible if the working capital adjustment has already factored in their impact.

Mentor Graphics (Noida) (P) Ltd. v. DCIT
109 ITD 101 · 2007 · ITAT
85
citing judgments

A working capital adjustment is mandated and a prerequisite for correctly determining the Arm's Length Price (ALP) under Rule 10B(1)(e) and Rule 10B(3) of the Income Tax Rules, 1962. This adjustment accounts for differences in working capital and outstanding receivables between the assessee and comparable companies.

Avenue Asia Advisors Pvt. Ltd. v. DCIT
398 ITR 120 · 2017 · High Court
84
citing judgments

The Delhi High Court holds that a detailed functional and working capital analysis, considering various factors, is essential before treating outstanding receivables as a separate international transaction for transfer pricing adjustments on notional interest. Simply making an adjustment based on receivables alone without such study distorts the transaction's character.

Indo Rama Synthetics (I) Ltd. v. CIT
330 ITR 363 · 2011 · Supreme Court
74
citing judgments

For Minimum Alternate Tax (MAT) under Section 115JB, the book profit must reflect the true working results of the company. Capital receipts that are not income cannot be included in book profit, and adjustments based on notes on accounts can be made to arrive at the real profit.

Huawei Technologies India Pvt. Ltd. v. JCIT
101 Taxmann.com 313 · 2019 · ITAT
67
citing judgments

Working capital adjustments are permissible and crucial for comparability analysis when determining the arm's length price of international transactions, especially when an assessee's claim for such adjustment has been denied.

ITO v. E Value Serve.com
75 Taxmann.com 195 · 2016 · Reported
60
citing judgments

In transfer pricing analysis, demanding daily balances for working capital adjustments is impractical and improper; adjustments should be based on opening and closing working capital. Transfer pricing inherently involves estimation to ensure comparability.

Genesis Integrating Systems India Pvt Ltd. v. DCIT
53 SOT 159 · 2012 · ITAT
57
citing judgments

Companies with significantly different turnovers (e.g., one above Rs. 200 crores and another below) cannot be considered comparable in transfer pricing analysis. Turnover is a relevant factor in assessing comparability.

Judgments citing working capital adjustment

Hetero Labs Limited, Hyderabad vs. ACIT, Central Circle-3(4), Hyderabad

In the result, the appeal of Revenue in ITA No

ITA 312/HYD/2023[2017-18]Status: DisposedITAT Hyderabad21 May 2024AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarआ.अपी.सं / Ita Nos.312 & 313/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2017-18 & 2018-19) Hetero Labs Limited, Vs. The Assistant Commissioner Of Hyderabad. Income Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent आ.अपी.सं / Ita Nos.348 & 349/Hyd/2023 (िनधा"रण वष" / Assessment Years: 2017-18 & 2-18-19) The Assistant Vs. Hetero Labs Limited, Commissioner Of Income Hyderabad. Tax, Central Circle – 3(4), Pan : Aaach5506R Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

For Appellant: Shri D. Prabhakar Reddy, AdvocateFor Respondent: Shri M.Vijay Kumar, CIT-DR
Section 143(3)

been held that no additional imputation of interest on the outstanding receivables is warranted if the pricing/profitability is more than the working capital adjusted margin of the comparables. In the opposition, the Id. DR relied on a later order dated 6.7.2015 passed by the Tribunal in the case of Techbooks ... cannot be construed as an international transactions is hereby rejected and dismissed. 5.6. We find that the Id. AR vehemently argued that the working capital adjustment has been granted by the Id. 'TPO to the assessee for both the years and hence, there cannot be further imputation of interest

The Asstt. Commissioner of Income Tax, Circle 2 (1)(1), Ahmedabad vs. M/S. Intas Pharmaceuticals Limited, Ahmedabad

In the result, both the appeals filed by the Assessee as well as Revenue are partly allowed for statistical purpose

ITA 2128/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad15 May 2024AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2012-13

Section 35

transaction. (d) That in the facts and circumstances of the case and in law, the learned CIT(A) ought to have appreciated that working capital adjustment was factored by the appellant company while fixing the sale price and hence it takes into account the impact of outstanding trade receivable ... came to Rs.1,08,78,100/- 8. We have heard both the parties and perused all the relevant material available on record. The working capital adjustment given by the assessee company while fixing the sale price and which has an impact of outstanding trade receivable on profitability while having sale

Intas Pharmaceuticals Ltd., Ahmedabad vs. The Asstt. Commissioner of Income Tax, Circle 2 (1)(1), Ahmedabad

In the result, both the appeals filed by the Assessee as well as Revenue are partly allowed for statistical purpose

ITA 1787/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad15 May 2024AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2012-13

Section 35

transaction. (d) That in the facts and circumstances of the case and in law, the learned CIT(A) ought to have appreciated that working capital adjustment was factored by the appellant company while fixing the sale price and hence it takes into account the impact of outstanding trade receivable ... came to Rs.1,08,78,100/- 8. We have heard both the parties and perused all the relevant material available on record. The working capital adjustment given by the assessee company while fixing the sale price and which has an impact of outstanding trade receivable on profitability while having sale

Kennametal India Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-4(3)(1), Bangalore

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

ITA 506/BANG/2022[2017-18]Status: DisposedITAT Bangalore15 May 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri T. Suryanarayana, Sr. A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 143(3)Section 92C

dismissed as not pressed. 15. With regard to ground Nos.2.15 & 2.16, this issue required to be considered by the ld. AO while granting working capital adjustment. Ordered accordingly. 16. In the result, appeal of the assessee is partly allowed for statistical purposes. Order pronounced in the open court on 15th

Poclain Hydraulics Private Limited, Pondicherry vs. DCIT, Chennai

In the result, appeal filed by the assessee is allowed for

ITA 1241/CHNY/2017[2010-11]Status: DisposedITAT Chennai10 May 2024AY 2010-11

Bench: Shri Aby T Varkey, Hon’Ble & Shri Jagadish, Hon’Bleआयकर अपील सं./Ita No.: 1241/Chny/2017 िनधा"रण वष" / Assessment Year: 2010-11 Dcit, M/S. Poclain Hydraulics Private V. Corporate Circle -5(2), Limited, Nungambakkam, No. 131/2, Kothapurinatham Chennai. Road, Mannadipet Commune Panchayat, Thiruvandarkoil, Puducherry – 605 102. [Pan: Aaecp-0947-Q]

For Appellant: Shri. S.P. Chidambaram, AdvocateFor Respondent: Shri. Suresh Guduri, JCIT

आयकर अपीलीय अिधकरण, ‘डी’ "यायपीठ, चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘D’ BENCH, CHENNAI "ी एबी टी वक", "याियक

Goldman Sachs Services Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

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

ITA 298/BANG/2021[2016-17]Status: DisposedITAT Bangalore24 Apr 2024AY 2016-17

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri Madhur Agarwal, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 144C(10)Section 92CSection 92C(3)

relying upon the information not available in public domain while carrying out the benchmarking analysis under the Act. 1.16 Not granting working capital adjustment 1.16.1 The Hon'ble DRP/ learned AO / T PO have erred in law by disregarding the Section 92C of the Act and Rule ... Rules by not considering the working capital adjustment while computing the net profit margin which constitutes difference if any, between the comparable uncontrolled transactions or between the enterprises entering into such transactions, which could materially affect the amount of net profit margin in the open market

Thermax Babcock & Wilcox Energy Solution Limited, Mumbai vs. Addl/Jt/Dy/CIT/Asstt/ITO/NFAC, Delhi

ITA 739/MUM/2022[2017-18]Status: DisposedITAT Mumbai04 Apr 2024AY 2017-18

Bench: Shri Vikas Awasthy & Shri Amarjit Singh, Accountαντ Μεμβer

For Appellant: Dhanesh Bafna a/wFor Respondent: Anil Sant

Page 1 ITA No.739/Mum/2022 Thermax Babcock & Wilcox Energy Solutions Ltd. Vs. DCIT, Circle 2(3)(1) IN THE INCOME TAX

Alcatel Lucent India Ltd, New Delhi vs. ACIT, Central Circle-15, New Delhi

In the result, the appeal is partly allowed

ITA 1447/DEL/2022[2018-19]Status: DisposedITAT Delhi20 Mar 2024AY 2018-19

Bench: Shri Saktijit Dey, Vice- & Shri Narendra Kumar Billaiyaassessment Year: 2018-19

Section 143(3)Section 144C(13)

assessment year 2017-18 upheld the adjustment. 32. Before us, learned counsel appearing for the assessee submitted, since, learned DRP has allowed working capital adjustment, no notional interest can be computed on outstanding receivable as it has already been subsumed in the working capital adjustment. He submitted, while deciding assessee ... reflects international transactions intended to benefit the Associated Enterprises. (3) Whether the assessee has already factored the impact of outstanding receivables on the working capital adjustment. 38. If we examine the facts of the present case in the context of the principles laid down by the Hon'ble Delhi High

Cbre South Asia (P) Ltd., New Delhi vs. ACIT Circle-5(2), New Delhi

In the result, the appeal by the assessee is dismissed

ITA 9078/DEL/2019[2015-16]Status: DisposedITAT Delhi08 Mar 2024AY 2015-16

Bench: Sh. Saktijit Dey & Sh. N. K. Billaiyaassessment Year: 2015-16 Cbre South Asia (P) Ltd. Vs. Acit Ground Floor, Pti Building, Circle- 5 (2) 4 Parliament Street, New Delhi New Delhi-110005 Pan No.Aaacc9308A (Appellant) (Respondent) Appellant By Mr. Kshitij Bansal, Ca Respondent By Sh.Rajesh Kumar, Cit (Dr) Date Of Hearing: 05/03/2024 Date Of Pronouncement: 08/03/2024

Section 143Section 144CSection 271(1)(c)Section 92CSection 92C(3)Section 92D

rule 10CA(2) of the Rules: 3.1.5 applying/not applying/incorrectly applying certain filters for accepting companies comparables; and 3.1.6 not providing the benefit of working capital adjustment to the Appellant disregarding difference in level of working capital assumed by the Appellant vis-à-vis comparable companies. Common ground 4.1 That

Medtronic Engineering and Innovation Center Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle -5(1), Hyderabad

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

ITA 225/HYD/2021[2016-17]Status: DisposedITAT Hyderabad06 Mar 2024AY 2016-17

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri Aliasgar Rampurwala and Shri Pratik, ARsFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 143(3)

appeal has been filed on as many as 11 grounds, at the time of arguments, all the grounds except the grounds relating to working capital adjustment and interest on External Commercial Borrowing (ECB) are given up. Now what remains to be adjudicated are these two grounds only. 3. Insofar ... working capital adjustment is concerned, it was denied by the Revenue authorities on the grounds that the assessee has not demonstrated that the working capital differences had impacted its profits; that the segmental working capital is not disclosed in the annual reports of the comparable companies; and that cost

Jubilant Pharmova Ltd., Uttar Pradesh vs. ACIT-1, Moradabad, Uttar Pradesh

In the result, the appeal of the assessee on this ground is partly allowed

ITA 526/DEL/2022[2017-18]Status: DisposedITAT Delhi05 Mar 2024AY 2017-18

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. K. M. Gupta, AdvFor Respondent: Sh. Rajesh Kumar, CIT- DR
Section 143(3)Section 144B

length by the Ld. DRP, while determining the ALP of the primary transaction i.e., Exports transaction, the ld. DRP had allowed working capital adjustment to the assessee which takes into account the outstanding receivables and payables of the assessee vis-à-vis the comparables for determination of ALP. Thus ... separate international transaction. 6 Jubilant Pharmova Ltd. 11. It was submitted that the Ld. DRP has failed to appreciate that the working capital adjustment subsumes the adjustment on account of receivables and payables. Since the adjustment regarding outstanding receivables have already been accounted for under the working capital adjustment

Concentrix Daksh Services India Pvt. Ltd., Gurgaon vs. ACIT, Circle-4(2), New Delhi

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

ITA 485/DEL/2021[2016-17]Status: DisposedITAT Delhi05 Mar 2024AY 2016-17

Bench: Sh. Saktijit Dey, Vice-Dr. B. R. R. Kumar

For Appellant: Sh. Ankul Goyal, AdvFor Respondent: Sh. Rajesh Kumar, CIT(DR)
Section 143(3)Section 92C

transaction and since the Hon'ble DRP/Learned AO/Learned TPO has determined the primary international transaction at an arm's length price after considering working capital adjusted margins of comparable companies, no separate adjustment can be made for such inter-company receivables and the same has been favourably upheld ... arising out of international transaction of provision of ITS are closely linked and as TPO has determined the International transactions at ALP considering working capital adjusted margins of comparable company's, no separate adjustment should be made.  Working capital adjustment takes into account the impact of outstanding receivables on profitability

At Kearney Ltd.- India Branch Office, Gurgaon vs. DCIT, Circle- 1(1)(1), International Taxation, New Delhi

In the result, appeals of the Assessee’s in ITA Nos

ITA 960/DEL/2018[2013-14]Status: DisposedITAT Delhi28 Feb 2024AY 2013-14

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 234ASection 271(1)(c)Section 27l

international transaction. • Amount receivable/payable arising out of international transactions of sales are closely linked and, no separate adjustment should be made. • Working capital adjustment takes into account the impact of outstanding receivables on profitability and therefore, no further imputation of interest ought to be warranted. AT Kearney Limited vs. DCIT ... section 92B of the Act, the outstanding receivables constitute a separate international transaction which is required to be bench marked separately. The working capital adjustment does not subsume the invoices which are raised during the year and accordingly interest is to be separately computed for outstanding receivables. Inter-company services

At Kearney Ltd.- India Branch Office, Gurgaon vs. DCIT, Circle- 1(1)(1), International Taxation, New Delhi

In the result, appeals of the Assessee’s in ITA Nos

ITA 959/DEL/2018[2012-13]Status: DisposedITAT Delhi28 Feb 2024AY 2012-13

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 234ASection 271(1)(c)Section 27l

international transaction. • Amount receivable/payable arising out of international transactions of sales are closely linked and, no separate adjustment should be made. • Working capital adjustment takes into account the impact of outstanding receivables on profitability and therefore, no further imputation of interest ought to be warranted. AT Kearney Limited vs. DCIT ... section 92B of the Act, the outstanding receivables constitute a separate international transaction which is required to be bench marked separately. The working capital adjustment does not subsume the invoices which are raised during the year and accordingly interest is to be separately computed for outstanding receivables. Inter-company services

DCIT, Circle- 1(1)(1), International Taxation, New Delhi vs. A.T. Kearney Ltd., Gurgaon

In the result, appeals of the Assessee’s in ITA Nos

ITA 1306/DEL/2018[2013-14]Status: DisposedITAT Delhi28 Feb 2024AY 2013-14

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 234ASection 271(1)(c)Section 27l

international transaction. • Amount receivable/payable arising out of international transactions of sales are closely linked and, no separate adjustment should be made. • Working capital adjustment takes into account the impact of outstanding receivables on profitability and therefore, no further imputation of interest ought to be warranted. AT Kearney Limited vs. DCIT ... section 92B of the Act, the outstanding receivables constitute a separate international transaction which is required to be bench marked separately. The working capital adjustment does not subsume the invoices which are raised during the year and accordingly interest is to be separately computed for outstanding receivables. Inter-company services

DCIT, Circle- 1(1)(1), International Taxation, New Delhi vs. A.T. Kearney Ltd., Gurgaon

In the result, appeals of the Assessee’s in ITA Nos

ITA 1305/DEL/2018[2012-13]Status: DisposedITAT Delhi28 Feb 2024AY 2012-13

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 234ASection 271(1)(c)Section 27l

international transaction. • Amount receivable/payable arising out of international transactions of sales are closely linked and, no separate adjustment should be made. • Working capital adjustment takes into account the impact of outstanding receivables on profitability and therefore, no further imputation of interest ought to be warranted. AT Kearney Limited vs. DCIT ... section 92B of the Act, the outstanding receivables constitute a separate international transaction which is required to be bench marked separately. The working capital adjustment does not subsume the invoices which are raised during the year and accordingly interest is to be separately computed for outstanding receivables. Inter-company services

Supermax Personal Care P. Ltd., Thane vs. Dy CIT -3(4), Mumbai

In the result, all the three appeals filed by the assessee are dismissed in above terms

ITA 687/MUM/2021[2016-17]Status: DisposedITAT Mumbai26 Feb 2024AY 2016-17

Bench: Ms. Kavitha Rajagopal & Shri Gagan Goyal

For Appellant: Shri Subhash Gupta & Shri AjinkyaFor Respondent: Shri Rajesh Kumar Yadav, Ld. DR
Section 250Section 32(1)Section 32(1)(iia)Section 92C

receivables on its net operating margin was benchmarked along with other international transactions to which they are closely inter- linked, by undertaking a working capital adjustment. 9. without prejudice to the above, the learned TPO failed to appreciate that the Assessee has inherently factored interest element on outstanding receivables from

Brandix Apparal India Private Limited, Visakhapatnam vs. The Assistant Commissioner of Income Tax, Circle - 5(1), Visakhapatnam

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

ITA 627/VIZ/2018[2014-15]Status: DisposedITAT Visakhapatnam13 Feb 2024AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble(Through Hybrid Hearing) आयकरअपीलसं./ I.T.A. No.627/Viz/2018 ("नधा"रणवष"/ Assessment Year : 2014-15) Brandix Apparel India Private Vs. Assistant Commissioner Of Limited, Income Tax, Apsez, Pudimadaka Road, Circle-5(1), Atchutapuram Mandal, Visakhapatnam. Visakhapatnam – 530011. Pan: Aaccb 6569 L (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Assessee By : Sri Darpan Kriplani ""याथ"क"ओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr

For Appellant: Sri Darpan KriplaniFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 10ASection 142(1)Section 143(2)Section 143(3)Section 92C

impact of difference on the pricing, cost and profits. Even before us, the Ld. AR has not provided any documents regarding the working capital adjustments. Following the principles of natural justice, in order to provide one more opportunity to the assessee, we hereby direct the Ld. AO / TPO to consider ... impact of working capital adjustments of the assessee company and appropriate material differences with that of the comparable companies and decide on this issue accordingly. We also direct the assessee to submit necessary documentation to the Ld. AO / TPO on this issue. Accordingly, this ground raised by the assessee

Teejay India Private Limited, Visakhapatnam vs. The Assistant Commissioner of Income Tax, Circle - 5(1), Visakhapatnam

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

ITA 626/VIZ/2018[2014-15]Status: DisposedITAT Visakhapatnam13 Feb 2024AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble(Through Hybrid Hearing) आयकर अपील सं./(I.T.)I.T.A.No.626/Viz/2018 (िनधा"रण वष" / Assessment Year : 2014-15) Teejay India Private Limited Vs. Asst.Commissioner Of Apsez, Pudimadaka Road Income Tax Atchutapuram Mandal Circle-5(1) Visakhapatnam Visakhapatnam [Pan : Aaaco9452H] (अपीलाथ"/ Appellant) (""थ"/ Respondent) अपीलाथ" की ओर से/ Appellant By : Shri Darpan Kirpalani ""ाथ" की ओर से / Respondent By : Dr.Satyasai Rath, Cit(Dr) सुनवाई की तारीख / Date Of Hearing : 22.01.2024 घोषणा की तारीख/Date Of Pronouncement : 13.02.2024 आदेश /O R D E R Per Shri Balakrishnan S

For Appellant: Shri Darpan KirpalaniFor Respondent: Dr.Satyasai Rath, CIT(DR)
Section 142(1)Section 143(1)Section 143(2)Section 143(3)

have heard the rival contentions. We find that from the directions of the Ld. DRP that the assessee has not demonstrated the working capital adjustments before the Ld. Revenue Authorities while determining the ALP under TNM method both for the Tested Party and the comparables. In the case of Devi ... impact of the delay in collection of receivables would have a bearing on the working capital of the assessee. We find that these working capital adjustments on the ALP has been already factored in its pricing / profitability vis-à-vis that of its comparables. We therefore are of the considered

Teejay India Private Limited., Visakhapatnam vs. The ACIT, Visakhapatnam

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

ITA 44/VIZ/2017[2012-2013]Status: DisposedITAT Visakhapatnam13 Feb 2024AY 2012-2013

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble(Through Hybrid Hearing) आयकरअपीलसं./ I.T.(Tp).A. No.44/Viz/2017 ("नधा"रणवष"/ Assessment Year : 2012-13) Teejay India Private Limited, Vs. Assistant Commissioner Of Plot No. 15, Brandix India Apparel Income Tax, City Private Limited Sez, Circle-5(1), 2Nd Floor, Direct Pudimadaka Road, Atchutapuram, Taxes Building, Mvp Double Visakhapatnam – 530 011. Road, Visakhapatnam, Pan: Aaaco 9452 H Andhra Pradesh. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Assessee By : Sri Darpan Kirpalani ""याथ"क"ओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr

For Appellant: Sri Darpan KirpalaniFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 12Section 143(2)Section 143(3)Section 92C

quashed. The Ld. AR further elaborated that the Ld. AO has not considered the directions of the Ld. DRP with regard to working capital adjustment and hence the assessment order passed by the Ld. AO is bad in law. The Ld. AR in his written submissions relied on the case ... working capital, the Ld. DRP in para 2.1 of its order has directed the Ld. AO to compute the mean of the working capital adjustment in respect of the comparables retained. The Ld. AO in his order in para 5 while considering the other directions