“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

Gates India Pvt Ltd, Delhi vs. ACIT, Circle-10(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 2379/DEL/2022[2018-19]Status: DisposedITAT Delhi22 Aug 2024AY 2018-19

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia

For Appellant: Shri M.P. Rastogi, AdvFor Respondent: Shri Rajesh Kumar, CIT-(DR)

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 92CSection 92C(1)

receivables even to third parties and thus a different treatment is not expected on transactions with AE. The DRP had directed to allow working capital adjustment before working out the ALP but neither the TPO nor the AO allowed the same despite the directions of the DRP. Notwithstanding, even after ... allowing the working capital adjustment on the point, PLI is still better (22.58%) than the uncontrolled comparables (6.13% median) as demonstrated in preceding paras. I.T.A. No.2379/Del/2022 28 25.4 Identical issue cropped up before Hon’ble High Court of Delhi in the case of Pr. CIT vs. Kusum Healthcare

Pegasystems Worldwide India Pvt.Ltd., Hyd, Hyderabad vs. ITO, Ward-16(3), Hyderabad

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

ITA 342/HYD/2016[2011-12]Status: DisposedITAT Hyderabad07 Aug 2024AY 2011-12

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.342/Hyd/2016 (िनधा"रण वष"/Assessment Year: 2011-12) Pegasystems Worldwide Vs. Income Tax Officer India (P) Ltd Ward 16(3) Hyderabad Hyderabad Pan:Aaecp3453F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Cas Kranthi & Mrudulatha राज" व "ारा/Revenue By:: Shri M Vijay Kumar, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 19/06/2024 घोषणा की तारीख/Pronouncement: 07/08/2024 आदेश/Order

For Appellant: CAs Kranthi & MrudulathaFor Respondent: : Shri M Vijay Kumar, CIT(DR)

Section 10ASection 143(3)Section 144C(5)Section 92C

assessee has raised multiple grounds on various issues, including rejection of T.P documentation, rejection of use of multiple year data, negative working capital adjustment, inclusion of certain comparables and exclusion of certain comparables, but restricted its arguments only on the grounds relating to inclusion/exclusion of certain comparables. Therefore, we deem ... raised various grounds relating to other issues including computation of net margin, incorrect selection of filters, selection of multiple year data, negative working capital adjustment and adjustment for risk differences etc., Since the learned Counsel for the assessee restricted his submission with regard to comparables discussed by us in preceding

Samsung India Electronics Pvt. Ltd., Gurgaon vs. DCIT Circle-22(2), New Delhi

In the result, the appeal of the assessee is partly allowed in the aforesaid manner

ITA 9482/DEL/2019[2015-16]Status: DisposedITAT Delhi29 Jul 2024AY 2015-16

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.

For Appellant: S/Shri Himanshu S. Sinha & Bhuwan Dhoopar, AdvFor Respondent: S/Shri Mahesh Shah, CIT(DR) & Kanv Bali, Sr. DR

Section 142(1)Section 143(2)Section 144C(1)Section 144C(13)Section 92C

comparables. 27. That on the facts and circumstances of the case and in law, the Ld. DRP/AO/TPO have erred in denying working capital adjustment under Rule 10B(l)(e) for the purpose of determination of ALP to account for the difference in working capital employed by the Assessee ... comparable companies by ignoring the fact that working capital adjustment was allowed by Ld. TPO in AY 2005-06, 2006-07, AY 2010-11 and 2011-12 and by Hon’ble DRP in AY 2013-14. 28. That on the facts and circumstances of the case

Fare Portal India Private Limited, New Delhi vs. DCIT, Circle-7(1), Delhi

In the result, the appeal of the assessee in ITA No

ITA 497/DEL/2022[2017-18]Status: DisposedITAT Delhi26 Jul 2024AY 2017-18

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.

For Appellant: Shri Himanshu S. SinhaFor Respondent: Shri Mahesh Shah

Section 143(3)Section 92CSection 92C(3)Section 92D

Rules. 5. On facts and in law, the Revenue erred in incorrectly computing the net cost-plus margins including the working capital adjusted margins of the comparable companies selected by the Ld. TPO and not even sharing back-up calculations with the Appellant. 6. On facts ... transaction but a consequence of international transactions. 9. On facts and in law, the Hon’ble DRP erred in not appreciating that the working capital adjustment allowed to the Appellant subsumes the impact of any additional return on account receivables. 10. On facts and in law, the Revenue erred

Jushi India Fiberglass Private Limited, Lower Parel, Mumbai vs. DCIT, Circle 6(1)(2), Churchgate, Mumbai

In the results, in the comparability study after giving working capital

ITA 1163/MUM/2024[2020-2021]Status: DisposedITAT Mumbai18 Jul 2024AY 2020-2021

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Rahul Chaudhary, Hon’Ble

For Appellant: Ms. Chaitee Londhe, A/RFor Respondent: Shri Nihar Ranjan Samal, Sr. D/R

Section 143(3)Section 92B

above grounds of appeal hon’ble DRP and consequently the learned AO erred in facts and in law in not considering working capital adjustments for selected comparable companies. 8. Without prejudice to the above grounds of appeal, hon’ble DRP and consequently the learned AO erred in facts ... exclude the same from the final list of comparables. 11. We further find that the TPO has dismissed the claim of working capital adjustments on the ground that the assessee has failed to explain as to how by not treating the working capital adjustment would materially affect the amount

Azingo Soft Systems (India) Pvt.Ltd., Hyd, Secunderabad vs. DCIT, Circle-1(1), Hyderabad

In the result, the grounds of the assessee are allowed for statistical purposes

ITA 460/HYD/2015[2010-11]Status: DisposedITAT Hyderabad16 Jul 2024AY 2010-11

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

For Appellant: Shri S. Rama Rao, AR

Section 143(3)Section 144C(8)Section 92C

That on the facts and circumstances of the case and in law, the AO/DRP erred in making the adjustment towards outstanding receivables as working capital adjustment factors for such implications. Page 5 of 14 I.T.A. Nos. 460 & 331/Hyd/2015 17. Without prejudice to the above grounds, that on the facts ... urged at the time of hearing.” 5. The assessee has also raised the following additional ground(s): “Ground No. 18A Negative working capital adjustment The appellant submits that the Ld.TPO/DRP has erred in making a negative working capital adjustment of -0.92% while computing the adjustment u/s. 92CA

DCIT, Circle-1(1), Hyderabad vs. Azingo Soft Systems India Pvt. Ltd., Hyd, Hyderabad

In the result, the grounds of the assessee are allowed for statistical purposes

ITA 331/HYD/2015[2010-11]Status: DisposedITAT Hyderabad16 Jul 2024AY 2010-11

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

For Appellant: Shri S. Rama Rao, AR

Section 143(3)Section 144C(8)Section 92C

Tek Systems Global Services Private Limited, Hyderbad vs. DCIT, Circle-2(1), Hyderbad

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

ITA 487/HYD/2022[2018-19]Status: DisposedITAT Hyderabad05 Jul 2024AY 2018-19

Bench: Shri Laliet Kumar & Shri Manjunatha G.आ.अपी.सं /Ita No.487/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2018-19) Tek Systems Global Vs. Dy. C. I. T. Services (P) Ltd, Circle 2(1) Hyderabad Hyderabad Pan:Aabcf1518Q (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Ms. K. Amulya, Ca रधजस् व द्वधरध/Revenue By:: Shri Jeevan Lal Lavidiya, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 29/05/2024 घोर्णध की तधरीख/Pronouncement: 05/07/2024 आदेश/Order

For Appellant: Ms. K. Amulya, CAFor Respondent: : Shri Jeevan Lal Lavidiya

Section 143(3)Section 144BSection 144C(13)Section 270A

Objection No. 6(a): On the facts and circumstances of the case, and in law, learned TPO/learned AO erred in not granting working capital adjustment. 2.6.1 Having considered the submissions, we note that Rule 10B provides for making reasonably accurate adjustment to the uncontrolled comparable transaction to eliminate the material ... effects of differences on the price, cost or profits. The assessee has argued for working capital adjustment contending that there exist differences in the payable and receivable position between the assessee and the comparables. However, it was not demonstrated with any data or information as to the impact of such

Macromill Research India LLP, Hyderabad vs. DCIT, Circle-16(2), Hyderabad

In the result, appeal of the assessee is partly allowed

ITA 308/HYD/2017[2012-13]Status: DisposedITAT Hyderabad28 Jun 2024AY 2012-13

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

For Appellant: Shri Darpan Kirpalani, ARFor Respondent: Shri Kumar Pranav, CIT-DR

Section 143(3)

Private Limited and Crystal Voxx Ltd., which was excluded by the Revenue authorities. Apart from these two issues, assessee is challenging the negative working capital adjustment and also the computation of interest on outstanding receivables. 5. Learned DR, heavily placed reliance on the orders of the Revenue authorities and submitted ... assessee to include these two entities. Grounds are accordingly allowed in part. 11. Now, coming to the issue relating to negative working capital adjustment covered by Ground No. 8, learned AR brought it to our notice that in assessee’s own case for the assessment year 2010-11, learned

Oakton Global Technology Services Centre (India) Private Limited, Hyderabad vs. ITO, Ward-16(3), Hyderabad

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

ITA 309/HYD/2017[2012-13]Status: DisposedITAT Hyderabad12 Jun 2024AY 2012-13

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.309/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Oakton Global Technology Vs. Income Tax Officer Services Centre (India) (P) Ltd, Ward 16(3) Hyderabad Hyderabad Pan:Aaaco8824H (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ravi Bhardwaj, Ca राज" व "ारा/Revenue By:: Smt. Th Vijaya Lakshmi, Dr सुनवाई की तारीख/Date Of Hearing: 10/06/2024 घोषणा की तारीख/Pronouncement: 12/06/2024 आदेश/Order

For Appellant: Shri Ravi Bhardwaj, CAFor Respondent: : Smt. TH Vijaya Lakshmi, DR

Section 143(3)Section 144(5)

been aggregated for determination of ALP under TNMM. (ii) Not appreciating the fact that under TNMM, the impact of outstanding receivables on the working capital adjustments have already been taken into account in determining the arm's length margin hence there is no need of imputing interest on outstanding receivables ... ignored the objections raised by the assessee and has finally selected 13 comparables with average OP/OC of 20.05% and after allowing working capital adjustment, finally computed operating margin at 18.5%. Since the appellant margin was 11.87%, proposed TP adjustment of Rs.1,36,52,580/- to the provisions of software development

Clinasia Labs Private Limited, Hyderabad vs. ITO Ward1(4), Hyderabad

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

ITA 202/HYD/2021[2016-17]Status: DisposedITAT Hyderabad11 Jun 2024AY 2016-17

Bench: Shri Laliet Kumar & Shri Manjunatha G.

For Appellant: Shri Nemichand Sirvi, ARFor Respondent: Shri K. Meghnath Chowhan, DR

Section 143(3)Section 92C

acceptance of Assessee's claim regarding non inclusion of certain companies comparable company. (Ground No. 6) (iii) Non grant of working capital adjustment (Grd.No.9). These grounds (except grd.No.7) read as follows: "4. The lower authorities erred in including the following companies, even though they fail the higher threshold

Caterpillar India Private Limited, Chennai vs. DCIT Ltu-1, Chennai

The appeal stands partly allowed in terms of our above order

ITA 2749/CHNY/2017[2013-14]Status: DisposedITAT Chennai11 Jun 2024AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.2749/Chny/2017 (िनधा;रणवष; / Assessment Year: 2013-14) M/S. Caterpillar India P. Ltd. Dcit 7Th Floor, International Tech Park, बनाम/ Large Taxpayer Unit-1 Taramani Road, Taramani, Chennai. Vs. Chennai-600 113. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aabcc-4615-K (अपीलाथ"/Appellant) : (" थ" / Respondent) & Cross Objection No.22/Chny/2023 (In Ita No.2749/Chny/2017) (िनधा;रण वष; / Assessment Year: 2013-14) Dcit M/S. Caterpillar India P. Ltd. बनाम/ 7Th Floor, International Tech Park, Central Circle-3(3), Chennai-34. Taramani Road, Taramani, Vs. Chennai-600 113. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aabcc-4615-K (Cross-Objector) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Assessee By : Shri S.P.Chidambaram (Advocate)- Ld. Ar " थ"कीओरसे/Revenue By : Shri A.Sasikumar (Cit)- Ld. Dr सुनवाई की तारीख/Date Of Hearing : 29-05-2024 घोषणा की तारीख /Date Of Pronouncement : 11-06-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri S.P.Chidambaram (Advocate)- Ld. ARFor Respondent: Shri A.Sasikumar (CIT)- Ld. DR

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

Hartron Communications Ltd. (seg) Jindal Intellicom Ltd. 18. The learned AO, learned TPO and the Hon'ble DRP have erred in not granting working capital adjustment on account of difference in working capital of the Appellant vis-a-vis, entrepreneurial companies selected as comparable. I9. The learned AO/learned TPO/Hon ... selected by the assessee and by introducing certain new comparable entities. The Ld. TPO also denied certain economic adjustment viz. risk adjustment, working capital adjustments as claimed by the assessee. The forex gains / losses were treated as operating in nature. 2.3 The Ld. TPO proposed TP adjustments in each

Bundy India Ltd., Baroda vs. The DCIT, Circle-1(1), Baroda

In the result, the appeal preferred by the assessee is allowed in part

ITA 1764/AHD/2013[2007-08]Status: DisposedITAT Ahmedabad10 Jun 2024AY 2007-08

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

For Appellant: Shri Parin Shah, A.RFor Respondent: Date of Hearing

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

additional ground was raised by the assessee in this appeal, which is as under: “(i) The Appellant ought to have been granted working capital adjustment while determining the arm's length price of the International transactions by the Learned Assessing Officer/Transfer Pricing Officer ("Ld. AO/TPO) and/or ... refund U/s 244A is only consequential in nature and need not be adjudicated. The ground is dismissed. 14. Additional Ground no. 1: Working Capital adjustment 14.1 The assessee had raised an additional ground for granting working capital adjustment while determining the ALP of the international transactions. The Ld. A.R. submitted

Daeseung Autoparts India Private Limited, Kancheepuram vs. ACIT (OSD), Chennai

The appeal stand partly allowed in terms of our above order

ITA 752/CHNY/2017[2012-13]Status: DisposedITAT Chennai04 Jun 2024AY 2012-13

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.752/Chny/2017 (िनधा;रणवष; / Assessment Year: 2012-13) M/S. Daeseung Autoparts India Pvt. Ltd. Acit (Osd) Plot No,474, Mannur Village, Corporate Range-1, बनाम/ Vs. Valarpuram Post, Sriperumpudhur Taluk Chennai. Kanchipuram- 602 105. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccd-5629-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Vikram Vijayaraghavan (Advocate)- Ld. Ar " थ"कीओरसे/Respondent By : Shri G. Suresh (Jcit)- Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 28-05-2024 घोषणा की तारीख /Date Of Pronouncement : 04-06-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri Vikram Vijayaraghavan (Advocate)- Ld. ARFor Respondent: Shri G. Suresh (JCIT)- Ld. Sr. DR

Section 143(3)Section 144C(5)Section 154Section 92C

circumstances beyond its control. The import of raw material was commercial decision and it was fourth year of operations. The assessee claim of working capital adjustment was also not granted since the assessee could not establish the impact of the same on its profit margins. The assessee’s objection ... transactions and not to whole of transactions as directed by Ld. DRP. The Ld. AR also sought various economic adjustments viz. depreciation adjustment, working capital adjustments and custom duty adjustments. The Ld. AR also argued on comparable matrix. 6. We find merits in the argument of Ld. AR that

Mckinsey Knowledge Centre India Pvt. Ltd., Haryana vs. DCIT Circle 16(1), Delhi

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

ITA 475/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Jun 2024AY 2017-18

Bench: Shri Shamim Yahya & Shri Sudhir Kumarmckinsey Knowledge Centre India Pvt. Ltd., Vs. Dcit, Circle 16 (1), 3Rd Floor, Block Iii, Delhi. Vatika Business Park, Sector 49, Sohna Road, Gurgaon – 122 018 (Haryana). (Pan : Aaccm2356G) (Appellant) (Respondent) Assessee By : Shri Porus Kaka, Sr. Advocate Shri Divesh Chawla, Advocate Revenue By : Shri Rajesh Kumar, Cit Dr Date Of Hearing : 24.04.2024 Date Of Order : 04.06.2024 Order Per Shamim Yahya: This Appeal By The Assessee Is Directed Against The Order Of The Assessing Officer Dated 21.01.2022 Pursuant To The Directions Issued By The Drp For The Assessment Year 2017-18. 2. Grounds Of Appeal Taken By The Assessee Read As Under :-

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR

have erred in not appreciating that the impugned international transactions (from which the inter- company receivables have arisen) were benchmarked by undertaking working capital adjustment by the Appellant which takes into account the difference in credit terms of the Appellant vis-a-vis the comparable companies. 15. On the facts ... Submissions of the Appellant 2.3 Without prejudice to Appellant's arguments of (1) outstanding receivables not being an international transaction, (2) comparing of working capital adjusted margins of comparables subsuming the impact, if any, of outstanding receivables and there being no need for a separate adjustment and (3) weighted average

M/S Kantar Gdc India Pvt. Ltd. (Formerly Tns India Pvt Ltd), Hyderabad vs. Dy. Commissioner of Income Tax, Circle-2(2), Hyderabad

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

ITA 2261/HYD/2017[2013-14]Status: HeardITAT Hyderabad03 Jun 2024AY 2013-14

Bench: Shri Mahavir Singh & Shri Manjunatha, G.आ.अपी.सं /Ita No.2261/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2013-14) M/S. Kantar Gdc India (P) Vs. Dy. C. I. T. Ltd (Formerly Tns India (P) Circle 2(2) Ltd, Hyderabad Hyderabad Pan:Aabcn2278F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate Harpreet Singh Ajmani राज" व "ारा/Revenue By:: Shri Shiva Sewak, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 15/05/2024 घोषणा की तारीख/Pronouncement: 03/06/2024 आदेश/Order

For Appellant: Advocate Harpreet Singh AjmaniFor Respondent: : Shri Shiva Sewak, CIT(DR)

Section 143(3)Section 144C(5)Section 271(1)(c)

services to AE's : a) Not appreciating the fact that the receivables are consequential/closely linked to the principal transactions; b) Under TNMM, the working capital adjustments undertaken take into account the impact of outstanding receivables of the controlled transactions vis-à-vis the uncontrolled transactions in determining

Satyam Venture Engineering Services Private Limited, Secunderabad vs. Assistant Commissioner of Income Tax, Central Circle -3(2), Hyderabad

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

ITA 192/HYD/2021[2016-17]Status: DisposedITAT Hyderabad31 May 2024AY 2016-17

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं / Ita-Tp No. 192/Hyd/2021 (धििाारण वर्ा / Assessment Year: 2016-17) Satyam Venture Assistant Commissioner Engineering Services Vs. Of Income Tax, Private Limited, Central Circle-3(2), Secunderabad Hyderabad [Pan No. Aafcs3287D] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

For Appellant: Shri E.V. Sri Krishna, ARFor Respondent: Ms. L. Sunitha Rao, CIT-DR

Section 143(3)Section 40

answered accordingly. 9. Now, coming to the issue of interest on receivables, learned AR submitted that the assessee is a debt free entity, working capital adjustment is not given and also that the assessee has not been charging any interest to non-AEs. He, therefore, submitted that there cannot

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

In the result, the appeal of Revenue in ITA No

ITA 349/HYD/2023[2018-19]Status: DisposedITAT Hyderabad21 May 2024AY 2018-19

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

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

In the result, the appeal of Revenue in ITA No

ITA 348/HYD/2023[2017-18]Status: DisposedITAT Hyderabad21 May 2024AY 2017-18

For Appellant: Shri D. Prabhakar Reddy, AdvocateFor Respondent: Shri M.Vijay Kumar, CIT-DR

Section 143(3)

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

In the result, the appeal of Revenue in ITA No

ITA 313/HYD/2023[2018-19]Status: DisposedITAT Hyderabad21 May 2024AY 2018-19

For Appellant: Shri D. Prabhakar Reddy, AdvocateFor Respondent: Shri M.Vijay Kumar, CIT-DR

Section 143(3)