Held that advances to suppliers and advances from customers are integral working capital adjustment and therefore such advances cannot be excluded in computing the working capital  adjustment. Reference to trade receivable and trade payables in the example given in Annexure to Chapter III of the OECD Transfer Pricing Guidelines 2010  should be construed as including advances to suppliers and advances from customers.    Tribunal also held that   a company which has passed the filter of manufacturing sales not less than 75 percent of total sales  only passed the company level test for qualifying as a comparable; since the said company has also service income to the extent of 17 per cent of its total revenue and no segmental information of the manufacturing activity is available  it cannot be considered as comparable for bench marking the international transaction of 100 percent manufacturing activity of  the appellant company. (AY. 2013-14)