Dabur India Ltd. v. Dy. CIT (2023)101 ITR 148 (Delhi) (Trib)

S. 92C : Transfer pricing-Arm’s length price-Interest on receivables-Not a separate international transaction-Net margin more than of comparables-Separate Benchmarking not required. Adjustment to be deleted.

Held That though receivables were an international transaction, which needed to be benchmarked separately, as pointed out by the Commissioner (Appeals), the margin of the assessee, both in fast moving commercial goods and non-fast moving commercial goods segment, was much higher than that of the comparables. Since benchmarking under both the segments had been accepted in the transfer pricing study, there was no infirmity in the order of the Commissioner (Appeals), and there was no reason to separately benchmark receivables. (AY.2010-11, 2011-12).