Tribunal held that non-granting of working capital adjustment was concerned, it was seen that in immediately preceding assessment year, Tribunal had occasion to consider this argument for grant of working capital adjustment. Accordingly the Tribunal directed to grant working capital adjustment and accordingly, remitted matter to file of TPO/A.O. for doing needful. (AY.2013-14)
Pitney Bowes Software India (P.) Ltd. v. Add. CIT (2018) 165 DTR 81 / 192 TTJ 778 (Delhi)(Trib.)
S.92C: Transfer pricing—Provision of software development services-Net Margin Method (TNMM) for benchmarking its international transaction of Provision of software development services-Working capital adjustment–Matter remanded.