2026 (9) TMI 1885

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....mmissioner of Income Tax (Appeals), Bengaluru (the learned CIT(A)). By that order, the learned CIT(A) partly allowed the assessee's appeal against the assessment order dated 30 January 2017 passed under section 143(3) read with section 144C(3) by the Assistant Commissioner of Income Tax, Circle-7(1)(2), Bengaluru (the learned Assessing Officer). 02. The Assessee has raised the following grounds of appeal: General grounds: 1. The assessment order dated 30 July 2024 passed by the Honourable Commissioner of Income Tax (Appeals) ['Hon'ble CIT(A)'] under section 250 of the Income-tax Act, 1961 ('the Act') is contrary to the facts and circumstances of the present case and is not in accordance with law. ....

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....The learned AO/ learned TPO/ Hon'ble CIT(A) erred in determining negative working capital adjustment despite the fact that the Appellant is captive service provider unlike the entrepreneurial companies selected as comparable. 8. The learned AO/learned TPO/ Hon'ble CIT(A) grossly erred in not providing an adjustment towards risk differential between the Appellant and the comparable companies. 9. The learned AO/ learned TPO/ Hon'ble CIT(A) has grossly erred in not rejecting the following companies a) Tech Mahindra Limited b) Mindtree Limited 10. The learned AO/learned TPO/ Hon'ble CIT(A) has grossly erred in rejecting companies that ought to have been accepted as comparable: ....

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....esent appeal would become redundant. 04. The learned authorized representative, Shri Ninad Patade, chartered accountant, reiterated these submissions and placed before us the order dated 20 February 2025 passed by the learned CIT(A) under section 154 read with section 250 of the Income-tax Act. Paragraph 5.2.1 of that order records that the learned CIT(A), following the decision of a coordinate Bench, deleted the negative working capital adjustment. 05. Dr. Divya K.J., the learned CIT-DR, submitted that if, pursuant to any order passed by the learned Assessing Officer, the assessee's margin falls within the permissible range, the appeal would become infructuous. 06. We have considered the rival submissions and perused the orders pa....