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2020 (1) TMI 1604 - AT - Income TaxTP Adjustment - Comparables for distribution segment of the assessee company - HELD THAT:- Comparable as functionally different with that of assessee and with high turnover need to be deselected. Adjustment of interest on receivables - Since the facts of the impugned assessment year are identical to the facts of the case decided by the Tribunal in assessee’s own case for A.Ys 2005-06 and 2014-15 therefore, respectfully following the same, we hold that if working capital adjustment is to be given, then, it subsumes the impact of outstanding receivables and payments by the assessee and, therefore, in the light of the ratio of the decision of the Hon’ble Delhi High Court in Kusum Healthcase Pvt. Ltd. [2017 (4) TMI 1254 - DELHI HIGH COURT], no adjustment is warranted on account of interest on receivables. Working capital adjustment - Respectfully following the decision of the Tribunal in assessee’s own case for A.Y. 2012-13 [2019 (1) TMI 636 - ITAT DELHI] we direct the AO/TPO to allow working capital adjustment to the assessee while working out the ALP of the international transaction. Appeal filed by the assessee is allowed.
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