https://www.taxtmi.com/caselaws?id=469591 Working capital differences must be factored into transfer pricing comparability under rule 10B(3) of the Income-tax Rules, 1962, so an arm's length analysis should be recomputed after granting opportunity to the assessee. A section 14A disallowance cannot be sustained on an ad hoc basis without proper computation; it requires fresh examination by the Assessing Officer after hearing the assessee. The note states that both disputed additions were remitted for reconsideration, with the remaining grounds not surviving for substantive determination. en-us Wed, 04 Dec 2024 00:00:00 +0530 Tue, 23 Jun 2026 19:00:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469591 Working capital differences must be factored into transfer pricing comparability under rule 10B(3) of the Income-tax Rules, 1962, so an arm's length analysis should be recomputed after granting opportunity to the assessee. A section 14A disallowance cannot be sustained on an ad hoc basis without proper computation; it requires fresh examination by the Assessing Officer after hearing the assessee. The note states that both disputed additions were remitted for reconsideration, with the remaining grounds not surviving for substantive determination. Case-Laws Income Tax Wed, 04 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469591