https://www.taxtmi.com/caselaws?id=469591 Working capital differences affect transfer pricing comparability and require reasonable adjustment under rule 10B(3) when determining the arm's length outcome. The transfer pricing computation should account for the working capital positions of the tested party and comparable companies, with an opportunity to address the recomputation. Disallowance of expenditure relating to exempt income cannot rest on an ad hoc calculation; it requires proper examination, a reasoned computation, and an opportunity of hearing before any determination is made. 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 affect transfer pricing comparability and require reasonable adjustment under rule 10B(3) when determining the arm's length outcome. The transfer pricing computation should account for the working capital positions of the tested party and comparable companies, with an opportunity to address the recomputation. Disallowance of expenditure relating to exempt income cannot rest on an ad hoc calculation; it requires proper examination, a reasoned computation, and an opportunity of hearing before any determination is made. Case-Laws Income Tax Wed, 04 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469591