Appellate Tribunal Partly Allows Appeal on Transfer Pricing Adjustments, Excludes Certain Comparables, Disallows Negative Working Capital Adjustment.

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....The Appellate Tribunal considered TP Adjustment issues, analyzing comparables like Eclerx Services Limited, Infosys BPO Limited, and TCS E-Serve Limited. Previous exclusions were maintained due to functional dissimilarity. R Systems International Limited was rejected due to a different accounting year, following the ruling in Mckinsey Knowledge Centre India Pvt. Ltd. ACE BPO Services Private Limited and Crystal Voxx Ltd. were not included as uncertainties remained. Negative working capital adjustment was disallowed based on Cordys Software India P. Ltd case. Interest on outstanding receivables was determined using LIBOR rates plus 200 points. The appeal was partly allowed.....