Assessee was engaged in business of trading of medical equipment, i.e., blood gas analysers and consumables. It followed a unique business model wherein it bought analysers and sold them to third parties, i.e., hospitals, medical institutions etc., booked revenue under trading segment and if customer was not willing to buy analysers, such instruments were installed at customer’s premises and cost of such analysers imported from AEs, was capitalized in books of account of assessee. TPO had accepted purchase price of such analysers for trading segment as at arm’s length, but determined arm’s length price of purchase of fixed assets (analysers) at Nil. Held that import of goods was substantiated by furnishing custom documentation, custom’s duty paid and TPO had not applied any method to benchmark said transaction. While treating purchase of capital goods as NIL, TPO failed to provide any comparable data which would have suggested that arm’s length price for purchase of capital goods can be NIL. Since same products purchased from same AE for same price in same year could not be held to be at arm’s length for trading goods and not at arm’s length for capitalised goods, adjustment made by TPO was to be deleted. Held that since there was delay in receivables from AE and in some instances, delay was substantial, it had to be ascertained what was average delay in case of AE and non-AE transactions and reason for delay had to be looked into.  Issue was restored to Assessing Officer for fresh adjudication.  (AY. 2014-15)