Tribunal held that as regards direct sales Compensation, direction  was given to  Assessing Officer to adopt average commission rate of  3.93 Per Cent. as appropriate rate for benchmarking As regards  bad  debts written off  adjustment made towards bad debts written off  to be deleted. As regards, royalty matter remanded.  The Tribunal observed that the order was being pronounced much after the expiry of 90 days from the date of conclusion of hearing on account of nationwide lock-down due to pandemic Covid-19 applying the exception to 90 day time limit for pronouncement of orders inherent in rule 34(5)(c) of the Income-tax (Appellate Tribunal) Rules, 1963. (AY. 2010-11, 2011-12)