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2024 (3) TMI 877 - AT - Income TaxTP Adjustment - working capital adjustment - HELD THAT:- Since the view taken in the cases of Parexel International Clinical Research (P.) Ltd. [2023 (3) TMI 1429 - ITAT BANGALORE] and also Parexel International (India) Private Limited [2023 (12) TMI 633 - ITAT HYDERABAD] is directly and substantially on the issue of allowability of working capital adjustment under identical circumstances, while respectfully following the same, we set aside the issue to the file of the learned Assessing Officer/learned TPO to decide the issue afresh, after considering the information furnished by the assessee. Benchmarking of the interest paid on ECBs - There is no denial of the fact that the term of the impugned ECB loan is not four years, but five years, and as observed by the learned DRP, such loan can have a spread of 300 bps. Also as perused the copies of the orders dated 29/01/2016 and 30/09/2016 under section 92CA(3) of the Act, evidencing the fact that the assessee paying interest on ECB loan at LIBOR+2.75% was accepted. We find that the payment of interest on ECB by the assessee at LIBOR+275 basis points need not be interfered with. Ground is accordingly allowed.
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