Working capital adjustment must be computed on actual figures from final comparables, not limited to an earlier percentage.

Working capital adjustment in transfer pricing had to be computed on actual figures from the final set of comparables, not confined to the earlier 0.23% reference. The final assessment had omitted the adjustment altogether, and the unaddressed ground on the correctness of computation was treated as a mistake apparent on record. The adjustment was therefore directed to be granted on the basis of the final comparables, and the miscellaneous petition was allowed.

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Issues: Whether the working capital adjustment in the transfer pricing computation had to be granted on the final comparables and computed on actual figures, instead of being confined to 0.23%.

Analysis: The order recorded that the earlier direction had allowed working capital adjustment at 0.23% as recommended by the TPO, but the final assessment omitted the adjustment altogether. It was also noticed that the second part of the assessee's ground, relating to the correctness of computation, had not been dealt with. The omission to consider the computation from the final set of comparables was treated as a mistake apparent on record.

Conclusion: The working capital adjustment had to be given on the basis of actual figures computed from the final list of comparables, and the miscellaneous petition was allowed.

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