https://www.taxtmi.com/caselaws?id=470843 Negative working-capital adjustments cannot increase comparable companies' average arithmetic profit margins where a captive software-service provider is funded by its associated enterprise and does not bear working-capital risk. Working-capital adjustments must account for risk differences between the tested party and comparables and should align comparables with the tested party's risk profile. The adjustment increasing the comparables' margin was unsustainable and was deleted. en-us Fri, 24 Jul 2020 00:00:00 +0530 Wed, 12 Aug 2026 10:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470843 Negative working-capital adjustments cannot increase comparable companies' average arithmetic profit margins where a captive software-service provider is funded by its associated enterprise and does not bear working-capital risk. Working-capital adjustments must account for risk differences between the tested party and comparables and should align comparables with the tested party's risk profile. The adjustment increasing the comparables' margin was unsustainable and was deleted. Case-Laws Income Tax Fri, 24 Jul 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470843