The Transfer Pricing Officer denied working capital adjustment on the ground that the assessee had failed to establish its impact on profits and separately treated overdue receivables from associated enterprises as an international transaction. The Tribunal held that once the comparables were selected by the Transfer Pricing Officer, it was his duty to examine and compute the working capital adjustment or record reasons for denying it. As neither party had furnished the requisite computation, the matter was restored to the Transfer Pricing Officer for fresh determination. The Tribunal further held that if, after allowing the working capital adjustment, the assessee’s margin falls within the arm’s length range, no separate transfer pricing adjustment on account of overdue receivables would survive. (AY. 2020-21).
Schneider Electric IT Business India (P.) Ltd. v. Dy. CIT [2025] 181 taxmann.com 342 / 128 ITR 57 (SN) (Bang.)(Trib.)
S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Working capital adjustment-Comparables selected by Transfer Pricing Officer-Matter remanded-Adjustment on overdue receivables consequential.[S.92CA]
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