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2020 (9) TMI 1051 - AT - Income TaxTP Adjustment - Comparable selection - HELD THAT:- Assessee is engaged in the business of rendering back office and related services including invoicing, collection, administration, support services includes customer services, ticketing, contract loading etc. to its Associated Enterprises (AEs) i.e. ;TRX Inc, USA, TRX Europe Limited and TRX Germany GmbH, Germany (herein referred to as AEs). The services rendered by the assessee to its AEs is predominantly related to travel and tourism industry. The assessee is also engaged in providing software maintenance support to TRX portfolio of software products and solutions which is essential an ITES, thus companies as functionally dissimilar with that of assessee need to be deselected. And also excluded for non adhering turnover filter decided. TPO not reducing the Working Capital Adjustment of 1.47% from the final list of ALP margin - HELD THAT:- As stated that the TPO has specifically provided for 1.47 % as per the TPO order however while computing the ALP, the TPO adopted Working Capital Adjustment of only 0.13%. We are of the view that this issue ought to have been raised in a Rectification Application. Assessee has not contended before the DRP that the Working Capital Adjustment ought to be 1.47% instead of 0.13% granted by the TPO while computing the ALP. Therefore Ground No.8 raised is rejected.
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