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2016 (4) TMI 1201 - AT - Income TaxTPA - working capital adjustment - Held that:- TPO’s main objection was that since assessee was maintaining consolidated accounts, therefore, the trade creditors/ debtors in regard to IT support service segments were not available separately. Ld. counsel has pointed out that as noted earlier that segmental details are available and, therefore, this objection does not survive. As regards the objections of ld. DRP that average day to day working capital deployment cannot be computed, we are of the opinion that this objection cannot be accepted because, as rightly observed by ld. DRP in AY 2009-10 that it is the average working capital deployment which is to be considered, which can be computed with referene to opening and closing balances of working capital deployed. Thus we direct the ld. TPO to allow working capital adjustment to assessee as per the directions given by ld. DRP in AY 2009-10, as noted earlier. Selection of comparable - Held that:- If the employee cost is more than 25% then the comparable is to be included in the list of comparables selected by TPO.
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