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2021 (4) TMI 240 - AT - Income TaxTP Adjustment - comparable selection - functional dissimilarity - HELD THAT:- Assessee is a company engaged in the business of software development and 100% subsidiary of Mavenir Systems Inc. US .Companies functionally dissimilar with that of assessee as captive service provider need to be deselected from final list. Working capital adjustment - TPO restricted the working capital adjustment at 1.63% - HELD THAT:- As relying on M/S. RAMBUS CHIP TECHNOLOGIES (INDIA) PVT. LTD., BANGALORE AND VICE-VERSA [2015 (7) TMI 1049 - ITAT BANGLORE] we direct Ld. AO/TPO to recompute the working capital adjustment in the case of comparables in actual. We note that in all the transfer pricing cases this Tribunal has been directing the Ld. AO/TPO to grant working capital on actual. Present assessee being a captive service provider there is minimal risk undertaken and therefore there is a necessity to provide adjustment to the margins of comparables in the final list to set apart the differences.
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