Held that companies whose turnover in the current year was more than Rs. 200 crores were to be excluded from the list of comparable companies. Functionally similar companies cannot be excluded from list of comparables. Working capital adjustment is directed to examine as per OECD guidelines. As regards interest on delayed realisation of trade receivables, prime lending rate not to be considered for determining interest rate. Matter remanded. (AY.2016-17)
Barracuda Networks India P. Ltd. v.Dy. CIT (2022)95 ITR 350 (Bang) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Comparables-Turnover more than Rs. 200 Crores to be excluded from list of comparables-Functionally similar companies cannot be excluded from list of comparables–Working capital adjustment-Directed to examine as per OECD guidelines–Interest on delayed realisation of trade receivables-Prime lending rate not to be considered for determining interest rate-Matter remanded. [S.92CA]