Transfer Pricing Adjustment Confirmed Due to Lack of Working Capital Adjustment Request by Assessee in Study Report.

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....TP Adjustment - working capital adjustment - No document whereby the assessee has made any request before the learned transfer pricing officer or before the learned dispute resolution panel with respect to granting of working capital adjustment. Even in the transfer pricing study report it could not be shown that assessee himself has claimed any working capital adjustment while preparing its comparability analysis - Additions confirmed - AT....