2023 (1) TMI 1074

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....Hardik Nirmal For the Revenue : Shri Manoj Kumar- CIT DR ORDER PER M. BALAGANESH (A.M): This appeal in ITA No.2535/Mum/2022 for A.Y.2018-19 preferred by the order against the final assessment order passed by the Assessing Officer dated 29/07/2022 u/s.143(3) r.w.s. 144C(13) of the Income Tax Act, hereinafter referred to as Act, pursuant to the directions of the ld. Dispute Resolution Pa....

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....provided includes fixing application bugs, compatibility checks, software upgrades and enhanced software, etc. in relation to softwares developed either by Sapient Group, or by third parties. Sapient Consulting Private Limited got amalgamated into the assessee w.e.f 01/04/2019 vide order passed by the Hon'ble National Company Law Tribunal (NCLT) dated 15/05/2020. During the year under consideratio....

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....tment. This goes to prove that assessee had indeed considered the working capital adjustment for the comparable companies in its Transfer Pricing Study Report (TPSR) itself. The workings for the said working capital adjustment together with the basis of arriving at the same are enclosed in pages 99 to 101 of the paper book, which is the Transfer Pricing Study Report. Since, Sapient's operating mar....

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.... representing submissions made before the ld. DRP. The assessee also stated that working capital adjustment had indeed been granted to the assessee either by the ld. TPO or by the ld. DRP, in the earlier years commencing from A.Y. 2011-12 onwards, as the case may be. The ld. AR before us drew our attention to the relevant pages of the paper book where working capital adjustment has been granted to....