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2018 (10) TMI 1902 - AT - Income TaxTP Adjustment - working capital and risk adjustment - HELD THAT:- DRP had rejected the prayer of the assessee for granting working capital and risk adjustment - it appears that neither the assessee nor the AR had come out with any convincing materials to justify the claim made before the Ld.Revenue Authorities - the objection raised by the Ld.AR is required to be reconsidered by the Revenue considering the intricacies of the business of the assessee. Hence we hereby remit the matter with respect to granting of working capital and risk adjustment back to the file of Ld.TPO for de-nova consideration, thereby affording one more opportunity to the assessee to present its case before the Ld.TPO on merits. Most of the selection of comparable companies except in the EDS Segment we have held against the Revenue - We are of the considered view that the entire exercise with respect to selection of comparable companies other than in the EDS Segment needs to be reworked afresh in order to arrive at the appropriate result based on the appropriate comparable companies. Therefore we hereby remit back the matter with respect to selection of comparable companies other than in the EDS Segment to the file of Ld.TPO for de-nova consideration.
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