9911796707
TMI Blog2023 (1) TMI 1074X X X X Extracts X X X X X X X X Extracts X X X X ..... 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. AR before us drew our attention to the relevant pages of the paper book where working capital adjustment has been granted to the assessee in the past commencing from A.Yrs.2011-12 to 2017-18. In fact, we also find that on the final set of comparables chosen by the DRP, the assessee had given the working capital adjustments for the said comparable companies which has been ignored by the lower authorities. Hence, we deem it fit to restore the issue to the file of the ld. TPO with a direction to grant working capital adjustment to the assessee after ex ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pment and technology consulting services (in short, SDS). The SDS services 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 consideration, Sapient had entered into several international transactions and specified domestic transactions on which the disputed transaction before us is only in respect of provision of software development and technology consulting services to its Associated Enterprises (AEs). The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... deed made and submitted by the assessee before the ld. TPO and also before the ld. DRP. This is evident from pages 210-218 of the paper book representing submissions made before the ld. TPO and pages 319-324 of the paper book 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 the assessee in the past commencing from A.Yrs.2011-12 to 2017-18. In fact, we also find that on the final set of comparable ..... X X X X Extracts X X X X X X X X Extracts X X X X
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