Working capital adjustment remitted for fresh consideration after incomplete taxpayer compliance and lack of supporting evidence.

Working capital adjustment remained unresolved because the assessee did not furnish the required details and supporting documents after the Tribunal's direction for reconsideration. The Court noted that only unsubstantiated calculations had been provided and that the giving-effect order was based on the material then available. As the record was incomplete, the matter was remitted for fresh adjudication on merits after the assessee uploads the necessary particulars and the supporting evidence, with an opportunity of hearing before the first respondent.

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Issues: Whether the impugned giving-effect order, passed after the Tribunal directed reconsideration of working capital adjustment, required interference and a fresh decision on merits.

Analysis: The Tribunal had directed the Transfer Pricing Officer to reconsider working capital adjustment in light of the assessee's averments and evidence. The petitioner did not furnish the requisite working capital details and supporting material sought in the subsequent communication, and had only placed calculations without proper authentication or substantiation. In view of the incomplete compliance, the Court found that the giving-effect order had been passed on the material available, but also considered it appropriate that the issue be reconsidered after the petitioner supplies the required particulars.

Conclusion: The matter was remitted to the first respondent to pass a fresh order on merits after the petitioner uploads the required details and supporting documents, and after hearing the petitioner.

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