Companies having turnover of more than 200 crores upto 500 crores have to be regarded as one category and those companies cannot be regarded as comparables with companies having turnover of less than 200 crores. Negative working capital adjustment shall not be made in case of a captive service provider as there is no risk and it is compensated on a total cost plus basis. (AY. 2013-14)
Tavant Technologies India (P.) Ltd. v. DCIT (2020) 185 ITD 309 (Bang.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Comparable-Turnover of more than 200 crores upto 500 crores-Working capital adjustment-Negative working capital adjustment shall not be made in case of a captive service provider as there is no risk and it is compensated on a total cost plus basis.