Held that neither of the lower authorities held the entity CV Ltd. not a functionally comparable entity as not satisfying the “FAR” analysis. Even if the outstanding receivables were accepted as having more than four months, that would not affect the relevant profit margin in the segment. Explanation (c) to section 92B treats such receivables as an international transaction. The Transfer Pricing Officer was to frame his fresh computation.(AY.2017-18)
Emerson Climate Technologies (India) Pvt. Ltd. v. ACIT (2023) 147 taxmann.com 359/ 102 ITR 43 (SN)(Pune) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Outstanding receivables-Directed to frame fresh computation.[S.92CA]