No-Risk Status & Working Capital Adjustment Allowed in TP Analysis: ITAT Delhi

Honda R&D (India) Private Limited Vs DCIT (ITAT Delhi) The ITAT Delhi considered the assessee’s appeal against the Dispute Resolution Panel’s order relating to transfer pricing adjustments for Assessment Year 2011-12. The assessee, engaged in providing market research and testing services to its associated enterprise on a cost-plus basis, challenged the rejection of certain comparable companies, denial of working capital adjustment, refusal of risk adjustment, use of single-year data, and denial of the benefit under Section 92C. On the issue of comparables, the Tribunal held th...