Tribunal held that exclusion of company from the comparable is set aside. Amount of export incentives is liable to be considered as part of operating revenue. Transfer pricing adjustment is to be restricted only to the extent of international transactions. TPO is directed to grant working capital adjustment as per the methodology suggested by DRP. (AY. 2014-15)
Tasty Bitte Eatables Ltd. v. ACIT (2021) 214 TTJ 643 (Pune)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Comprables-Exclusion of company from the comparable is set aside-Amount of export incentives is liable to be considered as part of operating revenue-Transfer pricing adjustment is to be restricted only to the extent of international transactions-TPO is directed to grant working capital adjustment as per the methodology suggested by DRP. [S. 144C]