Question of adjustment on negative working capital does not arise. Companies engaged in diversified activities and earning revenue from various activities and no segmental data available, companies not passing employee cost filter, cannot be taken as comparable. On facts rejection of rental expenses is held to be proper. (AY.2011-12)
Harman Connected Services Corporation India P. Ltd. v. Dy. CIT (2022)95 ITR 1 (Bang) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Working capital adjustment-Question of adjustment on negative working capital does not arise-Selection of comparables-Companies engaged in diversified activities and earning revenue from various activities and no segmental data available, companies not passing employee cost filter, cannot be taken as comparable-On facts rejection of rental expenses is held to be proper. [S.92CA]