The TPO refused to give working capital adjustment to the assessee in the transfer pricing proceedings. The assessee had furnished detailed calculation for adjustment on account of working capital before the DRP. The DRP directed the TPO to give working capital adjustment using OECD methodology and to apply SBI Prime Lending rate as interest rate and hence the Final Order passed by the Assessing Officer did not require any interference from the Tribunal (ITA No. 6662/Del/2014 dt. 04-01-2018) (AY. 2010-11)
ITO v. H & S Software Development & Knowledge Management Centre P. Ltd. (2018) 62 ITR 65/ 90 taxmann.com 333 (Delhi )( Trib.)
S. 92C : Transfer pricing – Arms’ length price – DRP directed the TPO to give working capital adjustment using OECD methodology and to apply SBI Prime Lending rate as interest rate and hence the impugned Order passed did not require any interference.