TP: Functionally Dissimilar Comparables Excluded, Working Capital Adjustment Must

MMSH Clinical Research Pvt. Ltd. Vs DCIT (ITAT Bangalore) Working Capital Adjustment is Mandatory – Functional Dissimilarity Costs Revenue – ITAT Excludes Several Comparables in TP Case Bangalore ITAT dealt with transfer pricing adjustments running into ₹5.04 crore. Assessee company was engaged in rendering backend support services such as medical writing, quality checks & programming for overseas clients. For AY 2021-22, the return declaring income of ₹65.87 lakh was filed. AO referred the international transactions to TPO, who made an adjustment of ₹5.04 crore. DRP affirmed the...