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2015 (11) TMI 1895 - AT - Income TaxTP Adjustment - working capital adjustment - as per Revenue was that no such working capital adjustment was claimed before the TPO and CIT(A) allowed the same without any verification - HELD THAT:- As order was passed by the TPO proposing an adjustment which was adopted by the AO while passing the order u/s 143(3) r.w.s.144C(4) - case of the assessee was that since the assessee was providing services to its associate enterprises, then it was working on lower prices for its services. On the other hand, if services were provided wherein the customers pays on later date, then the working capital adjustment is to be allowed to a company, which is providing the services on cash basis. We find that similar issue of allowing working capital adjustment to the assessee has been held in favour of the assessee by series of decision on various in DCIT Vs. Emptoris Technologies India Pvt. Ltd. [2015 (10) TMI 738 - ITAT PUNE] - CIT(A) on the other hand had placed reliance on the decision in Vedaris Technologies Pvt. Ltd. [2010 (3) TMI 898 - ITAT DELHI] and the OECD Guidelines. We find merit in the order of CIT(A) in directing the AO to grant working capital adjustment to the assessee on the basis of average credit/debit period for the year and commercial rate of interest. We find no merit in the grounds of appeal raised by the Revenue and the same are dismissed.
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