https://www.taxtmi.com/caselaws?id=469200 In transfer pricing proceedings under the TNMM, working capital adjustment must be examined on the basis of material and data, and the Transfer Pricing Officer cannot deny it by mere theoretical assertion, especially where the comparables were selected by the Revenue. The Tribunal indicated that the separate adjustment for interest on overdue receivables cannot stand independently if a working capital adjustment brings the assessee's margins within the arm's length range. The matter was remitted for fresh examination by the Assessing Officer/Transfer Pricing Officer, with the consequence that no separate receivables adjustment is warranted if working capital adjustment is allowed. en-us Thu, 04 Dec 2025 00:00:00 +0530 Tue, 09 Jun 2026 20:44:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469200 In transfer pricing proceedings under the TNMM, working capital adjustment must be examined on the basis of material and data, and the Transfer Pricing Officer cannot deny it by mere theoretical assertion, especially where the comparables were selected by the Revenue. The Tribunal indicated that the separate adjustment for interest on overdue receivables cannot stand independently if a working capital adjustment brings the assessee's margins within the arm's length range. The matter was remitted for fresh examination by the Assessing Officer/Transfer Pricing Officer, with the consequence that no separate receivables adjustment is warranted if working capital adjustment is allowed. Case-Laws Income Tax Thu, 04 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469200