Held  that export incentives should be included in the operating profit of the assessee as well as the comparables after ensuring that such export incentives were in respect of turnover of the current year only. The same effect should be given for working out the operating profit of the assessee, that is, the tested party, and the comparables. The duty drawback received against the duty paid should be considered part of the assessee’s operating profit. The matter was remitted to the Transfer Pricing Officer to verify that the export incentive was in respect of the turnover of the year under consideration. It was a settled position to apply the research and development filter with a threshold limit of 3 per cent. The Transfer Pricing Officer was directed to exclude L from the list of comparables. The matter regarding the rejection of G as a comparable is  remitted to the Transfer Pricing Officer to decide on the merits. That the transfer pricing adjustment should be restricted to the associated-enterprise-related transactions ; the Transfer Pricing Officer was directed to compute the adjustment accordingly Held that in keeping with the Organisation for Economic Co-operation and Development guidelines, working capital adjustment, as claimed by the assessee, should be allowed per actuals. The Transfer Pricing Officer is directed to consider the working capital adjustment and allow appropriate adjustment in arriving at the arm’s length price.(AY.2016-17)