Bechtel India (P.) Ltd. v. ACIT (2021) 188 ITD 460 / 86 ITR 544 (Delhi)(Trib.)

S. 92C : Transfer pricing-Arm’s length price-Export of customers electronic data-Comparable-Functionally different-Not acceptable as comparable-Interest receivable-No separate adjustment for interest on receivable was to be made.

Company engaged   in   activities of certification, recertification, safety audit, HSE management system for offshore and onshore oil and gas facilities functionally different companies cannot be accepted  as  comparable such as, Government company engaged in activity of providing consultancy for designing and engineering, project management and procurement of medical equipments, drugs and pharmaceutical etc,  Vocational training.  Tribunal also held that no separate adjustment for interest on receivable was to be made when working capital adjustment was already granted to assessee. (AY. 2013-14)c