“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

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

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

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

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

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

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

Rockwell Automation India Private Limited, Delhi vs. DCIT Circle-19(1), Delhi

Appeal is partly allowed for statistical purposes

ITA 3861/DEL/2024[2020-21]Status: DisposedITAT Delhi17 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalrockwell Automation India Deputy Commissioner Of Private Limited, Income Tax, Circle-19(1), Registered Address: 131, Vs. Delhi. Functional Industrial Are, Patparganj, Delhi-110092 Communication Address: 131, Functional Industrial Area, Patparganj, New Delhi. Pan-Aaccr3791A (Appellant) (Respondent) Assessee By Shri Ajit Jain, Ar Department By Shri Dharm Veer Singh, Cit-Dr Date Of Hearing 19.08.2025 Date Of Pronouncement 17.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Final Assessment Order Passed U/S 143(3) R.W.S 144C (13) Read With Section 144B Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 30.07.2024 For Assessment Year 2020-21. 2. Brief Facts Of The Case Ae That The Assessee Is A Company Engaged In The Business Of Manufacturing / Assembling Of Automation & Industrial Control Products / Systems. The Case Was Selected For Scrutiny & A Reference Was Made To The Tpo Due With Transactions With Ae’S. The Return Of Income Was Filed On Rockwell Automation India Private Limited Vs. Dcit 15.02.2021 Declaring Total Income At Rs.97,08,46,360/-. The Tpo Vide Its Order Dated 28.07.2023 Passed U/S 92Ca(3) Of The Act Has Proposed Adjustments Totaling To Rs. 26,12,44,668/-. Thereafter, The Ao Has Passed The Draft Assessment Order U/S 144C(1) Of The Act Dated 27.09.2023 Wherein The Ao Has Proposed The Additions Towards The Tp Adjustment As Per Tpo’S Order & Proposed To Assess The Total Income Of The Assessee At Rs.19,88,57,458/- & Further Proposed To Disallow Relief Claimed U/S 90/90A At Rs.1,04,60,287/-. Against The Draft Assessment Order, The Assessee Filed Objections Before The Drp.

Section 143(3)Section 144BSection 144C(1)Section 144C(10)Section 144C(13)Section 144C(8)Section 90Section 90ASection 92C

case for AY 2014-15 and AY 2017-18. 16. On facts and in law, the Revenue erred in not appreciating that the working capital adjustment subsumes the impact of any additional return on account receivables. 17. On facts and in law, the Revenue erred in arbitrarily applying a markup

Fil India Business and Research Services Private Limited, Delhi vs. Assessment Unit, Income-Tax Department, Delhi

In the result, appeal of the assessee is partly allowed

ITA 3245/DEL/2024[2020-21]Status: DisposedITAT Delhi14 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2020-21] Fil India Business & Research Vs Assessment Unit Services Pvt. Ltd., Private Studio- Income Tax Ncra/Ac/Ps/00/010B, Ground Department, Delhi Floor, Worldmark 1, Asset Area 11, Aerocity, Hospitality District, Indira Gandhi International Airport, Delhi-110037. Pan-Aabcf1572C Appellant Respondent Appellant By Shri Ravi Sharma, Adv. & Shri Shitiz Bansal, Ar Respondent By Shri Dharm Veer Singh, Cit Dr Date Of Hearing 18.08.2025 Date Of Pronouncement 14.11.2025 Order

Section 143(3)Section 920Section 92C(3)

risks assumed namely, * Snware Research Services Private Limited. * Keynote Financial Services Limited, and * Cheers Interactive India Private Limited 2.8. Denying the benefit of working capital adjustment to the Appellant by the Ld. TPO on frivolous grounds, in spite of the fact that the Hon'ble DRP had granted such benefit

Concur Technologies (India) Private Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle 2(2)(1), Bangalore

Appeal of the assessee is partly allowed as indicated above

ITA 2550/BANG/2024[2021-22]Status: DisposedITAT Bangalore11 Nov 2025AY 2021-22

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2021-22

For Appellant: Shri Chavali Narayan, CAFor Respondent: Dr Divya K J, CIT(DR)(ITAT), Bengaluru

Section 144Section 144BSection 144C

wrongly computing the operating margins of certain comparable companies. 12. The learned A01 TPO erred in law and facts by not granting working capital adjustment which was sought for and contended by the Appellant before the learned TPO and the Honorable DRP. 13. The learned AO/ TPO erred ... related party transactions of 25.59% but the transfer pricing officer has rejected the same. 21. The assessee further referred to the working capital adjustment not granted by the learned transfer pricing officer and if the same is granted the financial effect of extended credit terms or delay in collection from

Sap India Private Limited, Bangalore vs. Deputy Commissioner of Income-Tax, Circle 6(1)(1), Bangalore

In the result appeal filed by the assessee is partly allowed

ITA 704/BANG/2023[2019-20]Status: DisposedITAT Bangalore11 Nov 2025AY 2019-20

Bench: Shri Prashant Maharishi & Shri Soundararajan K, Jm

Section 115Section 143Section 144BSection 144CSection 234DSection 37Section 92C

case of the some of the companies. Further sum of the functionally comparable companies was also excluded. The assessee also requested for the working capital adjustment. As per ground No. 8 there is a short grant of TDS wherein the assessee claimed in its return of income ... exclusion of the certain comparable as well as inclusion of the certain comparable and thereafter the request of the assessee for granting the working capital adjustment was rejected. Page 4 of 13 Accordingly a final set of 12 comparable were retained whose 65th percentile margin was 13.30% 35th percentile margin

Ecoenergy Insights Ltd ( Formerly Known As Chubb Alba Control Systems P.Ltd), New Delhi vs. DCIT, Circle-4(2), New Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 2321/DEL/2022[2018-19]Status: DisposedITAT Delhi10 Nov 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR

Section 143(2)Section 144C(13)Section 144C(5)Section 147Section 92C

interfere with the order of the TPO. 7. With regard to R&D fees, DRP sustained benchmark made by the TPO, however, granted working capital adjustment by observing as under:- “3.4.2 The Panel has considered the submission. The TPO has considered these contentions which are raised before The Panel ... view that the benchmarking has been done correctly and no inter-reference is called for. The TPO, however, shall grant working capital adjustment, if relevant data and detailed working were given to him during TP proceedings. The TPO did not find anything relevant in the set of additional evidence

Weg Industries (India) Private Limited, Bengaluru vs. Assessing Officer, Bmtc Building

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

ITA 2501/BANG/2024[2021-22]Status: DisposedITAT Bangalore28 Oct 2025AY 2021-22

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2021-22

For Respondent: Shri Sumeet Khurana , CA

Section 143(3)Section 144BSection 144C(13)Section 153Section 92C(3)

precedent cited does not help the case of the assessee. Therefore the ld. DRP also rejected this. The assessee also requested for the working capital adjustment and also submitted a chart after working capital adjustment showing that median margin of the comparable is 1.86%. The ld. DRP rejected this contention ... material consumption.  Without verification of Internal TNMM its rejection is not proper.  Interest on overdue receivable is subsumed if the assessee is granted working capital adjustments. Even otherwise invoices are prepared in USD so applicability of SBI PLR is inappropriate. 16. The ld CIT DR vehemently supported the orders

Juniper Networks Solution India Private Limited, New Delhi vs. Assessment Unit, NFAC Itd, New Delhi

In the result, ground no 3 raised by the assessee is allowed in its favour

ITA 4400/DEL/2024[2020-21]Status: DisposedITAT Delhi24 Oct 2025AY 2020-21

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Juniper Networks Solution India Pvt. Ltd., Vs. Assessment Unit, Unit No.Iia, 06Th Floor, Dlf Centre, Nfac Itd, Parliament Street, Connaught Place, New Delhi – 110 001. (Pan : Aaecj1345A) (Appellant) (Respondent) Assessee By : Shri Sachit Jolly, Sr. Advocate Shri Sandeep Bhalla, Advocate Shri Anurag Singhal, Ca Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 05.08.2025 Date Of Order : 24.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 27.07.2024 Passed By The Income Tax Department, Assessment Unit U/S 143(3) Read With Section 144C(13)/144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

For Appellant: Shri Sachit Jolly, Sr. AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR

Section 115JSection 142(1)Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 92C

assessee on the segment carved out, ALP methodology, allocation key proposed, TNMM over RPM, application of quantitative filters and arithmetic error in margins, working capital adjustments and risk adjustments and comparable selection. After considering the submissions of the assessee and method adopted by the assessee for segment results ... objections, also filed detailed submissions. After considering the same, the DRP has sustained all the findings of the AO/TPO except allowed the working capital adjustment to be computed on the adjusted margins in accordance with the OECD guidelines. Accordingly, the TPO revised the weighted average adjusted mean of the comparable

Schneider Electric Private Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle 22(2), C. R. Building, Delhi

The appeal is allowed partly

ITA 5589/DEL/2024[2021-22]Status: DisposedITAT Delhi15 Oct 2025AY 2021-22

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2021-22 Schneider Electric Private Vs Dcit, Limited, Circle 22(2), C-56, Mayapuri Industrial Area, Delhi. Phase-2, West Delhi, Delhi – 110 064. Pan: Abacs1671F (Appellant) (Respondent) Assessee By : Shri Rohit Tiwari, Advocate & Ms Tanya, Advocate. Revenue By : Shri S.K. Jadhav, Cit-Dr Date Of Hearing : 20.08.2025 Date Of Pronouncement : 15.10.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Final Assessment Order Dated 28.10.2024 Passed By The Assessment Unit, Income-Tax Department (Hereinafter Referred To As The Ld. Ao) U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For Ay 2021-22. 2. Heard & Perused The Records. On The Basis Of Submission & Material On Record It Comes Up That Assesse/ Appellant (Sepl) Was Incorporated In 2018 As A Subsidiary Of Schneider Electric Industries Sas (A Wholly Owned Subsidiary Of Schneider Electric Se) & Belgium. It Is A Private Limited Company

For Appellant: Shri Rohit Tiwari, Advocate &For Respondent: Shri S.K. Jadhav, CIT-DR

Section 143(3)

companies selected as comparable in the TP order; 2.5 disregarding various comparability adjustments in determining the arm’s length profit margin including working capital adjustment; 4. In this segment, the Appellant renders business support services to its related parties. These services are agreed to be provided by SEPL ... same does not warrant determination of any separate arm’s length price under section 92C of the Act. It was submitted that once working capital adjustment is granted to the Appellant and the margin of the tested party is within the arm’s length range, no separate adjustment is warranted

Tupperware India Private Limited, Connaught Place New Delhi vs. National Faceless Assessment Centre Through Deputy Commissioner of Income Tax, Ip Estate New Delhi

The appeal is allowed partly

ITA 4475/DEL/2024[2020-21]Status: DisposedITAT Delhi15 Oct 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year : 2020-21

Section 143(3)Section 37Section 92BSection 92C

account of interest on delayed receivables. The ld. AR has submitted that the ld. TPO has ignored the fact that the post undertaking working capital adjustment of comparable companies selected in TP documentation, the margins earned by appellant are more than that of comparable companies. In this context ... case of Cotton Naturals, upheld the enhancement done by the ld. TPO. Since the case of assessee is that post undertaking working capital adjustment of comparable companies selected in TP documentation, the margins earned by appellant are more than that of comparable companies. We consider it appropriate to remit

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 partly allowed for statistical purposes

ITA 2346/BANG/2024[2021-22]Status: DisposedITAT Bangalore10 Oct 2025AY 2021-22

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

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 that the price charged by the tested party, it cannot be said that the extra credit allowed is not an independent

Panasonic India Private Ltd., Gurgaon vs. Neac, New Delhi

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

ITA 612/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Oct 2025AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganeshpanasonic India Pvt. Ltd, Vs. Neac, 12Th Floor, Ambience New Delhi Corporate Office, Tower-2, Ambience Island, Gurgaon (Appellant) (Respondent) Pan: Aadcp9391B

For Appellant: Shri Kanchan Kaushal, AdvFor Respondent: Shri S. K. Jadav, CIT (DR)

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

correct operating margin of the assessee company and recompute the adjustment ; b) Include Redington India Limited as a valid comparable; c) To allow working capital adjustment. The Learned DRP however upheld the adoption of TNMM as the MAM by the Learned TPO. The Learned TPO in the giving effect proceedings ... included Redington India Limited as a valid comparable and allowed working capital adjustment. However, the Learned TPO failed to correct the operating margin of the assessee for computation of TP adjustment under the distribution segment. Consequently, the Learned TPO passed an order dated 24-3-2021 to give effect

J P Morgan Services India Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 2(2)(1), Mumbai

In the result, assessee’s appeal is allowed

ITA 4781/MUM/2024[2020-21]Status: DisposedITAT Mumbai30 Sept 2025AY 2020-21

Bench: Shri Beena Pillai & Smt. Renu Jauhrij P Morgan Services India Vs. Deputy Commissioner Of Private Limited (‘The Income-Tax, Circle 2(2)(1) Appellant’) Aayakar Bhawan, Tower A Blk 9, Tower B Blk Maharishi Karve Road, 10, Tower C Blk 11, Nirlon New Marine Lines, Knowledge Park, Western Churchgate, Express Highway, Goregaon Mumbai-400020. East, Mumbai Suburban, 400063. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcd0503B Appellant .. Respondent

For Appellant: Shri Fenil BhattFor Respondent: Ms. Neena Jeph (CIT DR)

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 92D

facts and circumstances of the case and in law, the Ld.AO/Ld. TPO/Hon'ble DRP erred in not allowing/granting the working capital adjustment. 9. On the facts and circumstances of the case and in law, the Ld.AO/Ld. TPO/Hon'ble DRP erred in not allowing/granting the risk adjustments

Jubilant Generics Ltd., Noida vs. ACIT, Circle- 5(1)(1), G.B. Nagar

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

ITA 2004/DEL/2022[2018-19]Status: DisposedITAT Delhi24 Sept 2025AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

Section 143(3)Section 144BSection 92C

export of finished goods to its AEs and by ignoring that the compensation, if any, for outstanding receivables is already subsumed in the working capital adjustment undertaken with respect to primary international transaction On the facts and in the circumstances of the case and in law, the Ld. AO/TPO/DRP exceeded ... days and worked out interest on overdue receivables from AEs @ LIBOR + 400 bps. The Ld. Counsel contended that the appellant assessee had calculated working capital adjustment which subsumes the impact of interest cost; therefore, adjustment on account of interest on overdue receivables was not called for. Reliance was place

Technip India Limited, New Delhi vs. ACIT, Spl Range-9, New Delhi

In the result, Appeal No.6390/Del/2017 is partly allowed as per above terms

ITA 9852/DEL/2019[2015-16]Status: DisposedITAT Delhi17 Sept 2025AY 2015-16

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 6390/Del/2017 Assessment Year: 2013-14 Ita No. 9852/Del/2019 Assessment Year: 2015-16 Technip Energies India Vs. Additional Commissioner Of Limited, ( Formerly Known As Income Tax, Technip India Limited), Special Range-9, A-4, Sector 1, Institutional New Delhi Area, Noida – 201 301 Pan No. Aaack3349R (Appellant) (Respondent)

For Appellant: Shri Vishal Kalra, Adv., Shri Yishu GoelFor Respondent: Shri Dharm Veer Singh, CIT (DR)

Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 250Section 92C

without prejudice basis to the above grounds, the learned DRP/AO/TPO has erred by not allowing the Appellant's claim for working capital adjustment, 9. On a without prejudice basis to the above grounds, the learned DRP/AO/TPO has erred in not appreciating the fact that working capital adjustment factors ... without prejudice basis to the above grounds, the learned AO/TPO has erred by not allowing the Appellant's claim for working capital adjustment. The Hon'ble CIT(A) has erred in not providing any findings of the above facts; 9. On a without prejudice basis to the above grounds

Technip India Ltd., Noida vs. Addl.CIT, Special Range- 9, New Delhi

In the result, Appeal No.6390/Del/2017 is partly allowed as per above terms

ITA 6390/DEL/2017[2013-14]Status: DisposedITAT Delhi17 Sept 2025AY 2013-14

For Appellant: Shri Vishal Kalra, Adv., Shri Yishu GoelFor Respondent: Shri Dharm Veer Singh, CIT (DR)

Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 250Section 92C

Wns Business Consulting Services Pvt. Ltd., Mumbai vs. DCIT, New Delhi

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

ITA 3353/DEL/2017[2010-11]Status: DisposedITAT Delhi17 Sept 2025AY 2010-11

Bench: Shri S Rifaur Rahman & Shri Vimal Kumar

For Appellant: S/Shri Tarandeep Singh & SandeepFor Respondent: Shri Bhopal Singh, Sr. DR

Section 143(1)Section 143(2)Section 144C(1)Section 250(6)Section 92C(3)Section 92C(4)

Serve International Limited and TCS e-Serve Limited, Ld. CIT(A) has directed the Ld. TPO to use margins of comparable of working capital adjustment margin. 6. Learned Authorized Representative for the Revenue relied on order of Ld. AO. 6.1 Learned Authorized Representative for the Revenue referred to the decision ... comparable to the Appellant for benchmarking the international transaction of provision of IT enabled services, the Ld. TPO by giving benefit of working capital adjustment to the assessee. Pursuant to the order of Ld. CIT(A), the assessee has filed copy of letter dated 19.05.2017 before Ld. AO seeking appeal

Andante Foods LLP, Bangalore vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Bengaluru

Appeal are allowed, and appeal of the assessee is allowed for statistical purposes

ITA 1723/BANG/2024[2020-21]Status: DisposedITAT Bangalore15 Sept 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2020-21

For Respondent: Shri Harsha M., CA

Section 143(2)Section 143(3)Section 144C(1)Section 92C

tested party and TNMM is applied, the ld. TPO should have considered that the interest on overdue receivable is subsumed in the working capital adjustment. It was further stated that Page 8 of 12 the ld. TPO has not granted working capital adjustment even in his own comparable

D. E. Shaw India Private Limited, Hyderabad vs. DCIT., Circle-8(1), Hyderabad

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

ITA 1154/HYD/2024[2020-21]Status: DisposedITAT Hyderabad12 Sept 2025AY 2020-21

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1154/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2020-21) M/S. D.E. Shaw India Pvt. Dy. Commissioner Of Income Vs. Ltd., Hyderabad. Tax, Pan:Aaacd7214J Circle 8(1), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.P. Chidambaram, Adv. रधजस् व द्वधरध/Revenue By: Ms. U. Mini Chandran, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 01/09/2025 घोर्णध की तधरीख/Pronouncement: 12/09/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By M/S. D E Shaw India Pvt. Ltd. (“The Assessee”), Feeling Aggrieved By The Assessment Order Passed By The Learned Assessing Officer (“Ld. Ao”) U/S. 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (“The Act”) Dated 27.06.2024 For The A.Y. 2020-21. 2. At The Outset, It Is Seen That There Is A Delay Of 66 Days In Filing Of The Present Appeal, For Which The Assessee Has Filed Condonation Petition Explaining The Reasons For Delay In Filing Of The Appeal. As Per Record, The Appeal Was Required To Be Filed On Or Before

For Appellant: Shri S.P. Chidambaram, AdvFor Respondent: Ms. U. Mini Chandran, SR-DR

Section 143(3)

dated 28.12.2020]. ITA No.1154/Hyd/2024 8 11. In his second argument, the Ld. AR submitted that the assessee’s first prayer was to allow working capital adjustment while calculating the profit margin. The second prayer was that if a working capital adjustment is granted while calculating profit margin, then no separate ... adjustment on account of interest on receivables is required, since such impact is already subsumed in the working capital adjustment. Reliance was placed on the judgment of the Hon’ble Delhi High Court in Pr. CIT v. Kusum Healthcare Pvt. Ltd. (ITA No.765/2016, dated 25.04.2017). 12. Lastly, it was submitted

Apollo Tyres Ltd., Cochin vs. DCIT Corporate Cir 1(1), Kochi

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 679/COCH/2024[2020-21]Status: DisposedITAT Cochin10 Sept 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2020-21 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Acit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 10.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 115JSection 143(3)Section 154Section 35Section 92C

ought to be included in the final list of comparable companies, e. That the TPO/ AO/DRP erred in not allowing the benefit of working capital adjustment and risk adjustment, to the Appellant, without appreciating that such an adjustment is warranted in terms of Rule 10B(3) of the Rules

Apollo Tyres Ltd, Cochin vs. The Deputy Commissioner of Income Tax, Cochin

In the result, this ground of appeal stands allowed

ITA 1000/COCH/2024[2021-22]Status: DisposedITAT Cochin10 Sept 2025AY 2021-22

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2021-22 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Acit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 10.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 143(3)Section 14ASection 92C

ought to be included in the final list of comparable companies. e. That the TPO/ AO/DRP erred in not allowing the benefit of working capital adjustment and risk adjustment, to the Appellant, without appreciating that such an adjustment is warranted in terms of Rule 10B(3) of the Rules