Corrected Margins Segmental Financials and Working Capital Adjustment

The Delhi Bench of the Income Tax Appellate Tribunal restored multiple transfer pricing issues back to the file of the Assessing Officer and Transfer Pricing Officer for fresh verification and adjudication. 

The Tribunal held that the assessee’s claims regarding corrected margins of comparable companies, rectified segmental financials and entitlement to working capital and risk adjustments required proper factual examination which had not been adequately undertaken by the authorities below. 

Observing that the rectification application filed by the assessee had not been considered despite directions of the Dispute Resolution Panel, the Tribunal remanded the issues to the TPO/AO with directions to decide the matters afresh after granting proper opportunity of hearing.