https://www.taxtmi.com/caselaws?id=463453 ITAT held that listed companies with turnover exceeding Rs.200 crore must be excluded from comparable set for TP adjustment in the technical support services segment. Because exclusion left no reliable uncontrolled comparables, the transfer pricing comparison failed and, following OECD guidance, the assessee's claimed working capital adjustment was allowed to achieve a broader comparison. The issue of interest on outstanding receivables was remitted to the file of the AO/TPO for fresh consideration. en-us Thu, 09 Feb 2023 00:00:00 +0530 Mon, 01 Sep 2025 11:52:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463453 ITAT held that listed companies with turnover exceeding Rs.200 crore must be excluded from comparable set for TP adjustment in the technical support services segment. Because exclusion left no reliable uncontrolled comparables, the transfer pricing comparison failed and, following OECD guidance, the assessee's claimed working capital adjustment was allowed to achieve a broader comparison. The issue of interest on outstanding receivables was remitted to the file of the AO/TPO for fresh consideration. Case-Laws Income Tax Thu, 09 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463453