Negative working capital adjustment shall not be made in case of a captive service provider

Lam Research (India) Pvt. Ltd. Vs DCIT (ITAT Bangalore)

It was submitted that Working capital adjustment is made for the time value of money lost when credit time is given to the customers. The Assessee however does not bear any risk and has no working capital contingencies. The Assessee has not incurred any expenses for meeting the working capital requirement. The Assessee is running the business without any working capital risk as compared to the comparables. The Assessee does not bear any market risk as the services are p

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