Case Law Details
EIT Services India Pvt. Ltd. Vs JCIT (ITAT Bangalore)
It has been submitted by Ld.AR that working capital and risk adjustment was denied to assessee on the ground that assessee failed to demonstrate such differences could have any impact on assessee’s profit. It has been submitted by Ld.AR that the submissions advanced by assessee demonstrating computational impact has not been considered by the Ld.AO/TPO. Before us, Ld.AR submitted that it is an accepted principle upheld in various decisions of this Tribunal that working capital adjustment should be allowed on actuals. It has been submitted that all relevant details for computation of working capital adjustments was provided to the Ld.AO/DRP which was not considered. He placed reliance upon the decision of coordinate bench of this Tribunal in case of Huawei Technologies India (P.) Ltd. v. Jt. CIT [2019] 101 taxmann.com 313,wherein it has been held that the working capital has to be granted in actual.
On the contrary, Ld.CIT DR placed reliance upon orders passed by authorities below.
We have perused submissions advanced by both sides in light of records placed before us including the decision relied upon by Ld.AR in case of Huawei Technologies India Pvt. Ltd. (supra).
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