Held that functionally different companies are to be excluded from the comparable. Tolerance range of ±5 Per Cent. to be considered. Transaction of overdue receivables covered under capital financing is to be benchmarked separately irrespective of whether interest charged by assessee from non-associated enterprises-Rate of libor +3 Per Cent. for delayed remittances beyond allowable credit period.(AY.2012-13)
Excellence Data Research P. Ltd. v. ACIT (2022)100 ITR 74 (Trib) (SN) (Chenai)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Comparables-Functionally different-To be excluded-Tolerance range Of ±5 Per Cent. to be considered-Transaction of overdue receivables covered under capital financing is to be benchmarked separately irrespective of whether interest charged by assessee from non-associated enterprises-Rate of libor +3 Per Cent. for delayed remittances beyond allowable credit period. [S. 92CA]