Held that the average line rate charged by the assessee to its associated enterprise was higher than the rate charged by third-party vendors to the associated enterprise even after including the foreign currency loan interest of LIBOR + 3.25 per cent. to it and considering the credit period of 45 days (under its agreement with the associated enterprise) even after including the imputed interest cost to it. Therefore, the average line rate charged by the assessee to its associated enterprise in respect of provision of medical transcription services was at arm’s length vis-à-vis comparable interest cost adjusted rate charged by the third-party vendors to the associated enterprise. Addition was deleted. Adjustment margin was also deleted.(AY.2017-18)
Aquity Solutions India Pvt. Ltd. v. Dy. CIT (2022)100 ITR 15 (SN)(Mum) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Medical Transcription Services and Information Technology and Information Technology enabled Services-Receivable outstanding-Addition was deleted.