Tribunal held that no additional imputation of interest on outstanding receivables is warranted if pricing/profitability of assessee is more than working capital adjusted margin of comparables companies. Accordingly addition made on account of interest on receivables was deleted. Followed PCIT v. Kusum Health care (P) Ltd (2017)) 398 ITR 66 (Delhi)(HC). (AY. 2016-17)
ERM India (P.) Ltd. v. NEAC (2021) 91 ITR 24 (SN) / (2022) 192 ITD 115 (Delhi)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Interest on outstanding receivables-Adjustment is not warranted if pricing/profitability of assessee is more than working capital adjusted margin of comparables companies.