ITAT remitted the working-capital adjustment issue to the file...

ITAT remitted the working-capital adjustment issue to the file of the ld. TPO for fresh adjudication, holding that prior rejection for complexity was improper and that interest on overdue receivables would be subsumed if working-capital adjustment is allowed; ground No.2 thus allowed. A fresh claim for interest on compulsorily convertible debentures was remitted to the ld. AO for verification and quantification, directing the assessee to substantiate the claim and permitting deduction if in accordance with law. The disallowance under s. 40(a)(ia) in respect of reimbursements to the associated enterprise was directed to be deleted, the Tribunal holding the payments to be cost-to-cost reimbursements lacking an income element.