Transfer Pricing: Working capital adjustment should be allowed on actuals

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 work

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