Netapp India Marketing and Services Pvt. Ltd. v. ACIT (2022)95 ITR 91 (SN)(Bang) (Trib)

S. 92C : Transfer pricing-Arm’s length price-Comparables-Working capital adjustment-Interest on outstanding receivables. Matter remanded.

Held that  the Transfer Pricing Officer had not examined the remaining three companies also. All these companies were functionally comparable with the activities carried on by the assessee. Accordingly, all these companies needed to be examined by the Transfer Pricing Officer. Held that  working capital adjustment was required to be made in order to determine the arm’s length price of the transaction. Interest on outstanding receivables matter remanded.(AY.2016-17)