ACIT v. WNS Global Services (P.) Ltd. (2020) 182 ITD 59 (Mum.)(Trib.)

S. 92C : Transfer pricing-Arm’s length price-ITES services did not form a single composite transaction-Transactions cannot be aggregated-Extended credit period-Addition of notional interest is held to be not justified.

Dismissing the appeal of the revenue the Tribunal held that since transactions of assessee with its AEs did not form a single composite transaction and terms of each transaction was agreed separately by assessee with its AEs, approach of TPO aggregating international transactions was not appropriate. Tribunal also held that where assessee did not charge interest either from its AEs or from third parties towards extended credit period for payment of contract revenue for providing them ITES services, no notional interest was to be charged on receivables from AEs for such extended credit period. (AY. 2007-08)