Tribunal held that the assessee had been allowed working capital adjustment while computing the arm’s length price of the international transaction of the sale of services. Therefore, no separate benchmarking should be done of the outstanding receivables as these were part of the working capital of the assessee. Therefore the addition in relation to the delay in receipt of receivables from the associated enterprises was deleted. Relied on PCIT v. Kusum Health Care P. Ltd. (2017) 398 ITR 66 (Delhi)(HC). (AY. 2011-12)
Dy. CIT (LTU) v. EXL Service.Com (India) Pvt. Ltd. (2020) 83 ITR 11 (SN) (Delhi)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Working capital adjustment granted-Outstanding receivables part of working capital-No separate benchmarking warranted.