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TMI Blog2018 (5) TMI 1928X X X X Extracts X X X X X X X X Extracts X X X X ..... sible to allow any working capital adjustment - HELD THAT:- DRP directed the TPO to allow working capital adjustment in accordance with the decisions of the various benches of the Income Tax Appellate Tribunal. In the present case, no contrary decision was brought to our knowledge by the department. It is also noticed that the TPO allowed the working capital adjustment vide order dated 28.12.2015 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... le DRP has erred in law and in facts and circumstances of the case in granting working capital adjustment in the case of the assessee. 3. That the appellant craves leave to add, alter, amend or forego any grounds of the appeal raised above at the time of hearing." 3. The only grievance of the department relates to the directions given by the ld. DRP to the AO for granting working capital adju ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee had not been able to provide reliable and accurate data in respect of each segment so as to enable calculations of the working capital adjustments. The ld. DRP further observed that it is ubiquitous practice for companies to adjust their margins to cover interest costs, as such, working capital is typically an implicit cost which is recovered/recoverable from the customers. The ld. DRP also ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... T DR supported the order of the AO/TPO and submitted that since the complete informations were not provided by the assessee, therefore, it was not possible to allow any working capital adjustment. 8. In his rival submissions, the ld. Counsel for the assessee strongly supported the order passed by the ld. DRP. 9. We have considered the submissions of both the parties and carefully gone through ..... X X X X Extracts X X X X X X X X Extracts X X X X
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