Held that the facts and figures with regard to the business of the assessee had to be furnished. If information available in the public domain was insufficient, it was beyond the power of the assessee to produce the correct information about the comparable companies. The Revenue had the powers to compel production of the required details from the comparable companies. If that power was not exercised to find out the truth then it could not be said that the assessee had not furnished the required details and deny adjustment on account of working capital differences. Therefore, the issue was directed to the Transfer Pricing Officer/Assessing Officer for examination afresh after affording opportunity of being heard to the assessee.(AY.2016-17)
Aurigo Software Technologies P. Ltd. v. ITO (2022) 98 ITR 294 (Bang.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Working capital adjustment-Information regarding comparable companies not available in public domain-Matter remanded to Assessing Officer/Transfer Pricing Officer to decide issue afresh after affording opportunity of being heard. [S. 92CA]