Benefit of working capital adjustment not considered while computing ALP: Matter restored

Schneider Electric India Private Limited Vs ACIT (ITAT Delhi) ITAT Delhi held that the benefit of working capital adjustment while computing the ALP has also not been borne in mind hence matter restored to the file of TPO/ AO for fresh determination in accordance with law. Facts- Appellant was primarily engaged in the manufacturing of low voltage and medium voltage equipment and distribution of electrical equipment and also provided e content e catalogue IPO services, contract R&D support services and business support services to its AEs. TPO proposed to consider the aggregated margin of s...