Tribunal held that the outstanding sums under invoices are akin to loans advanced by the assessee to the foreign associated enterprise, and an international transaction according to the Explanation to section 92B . The Transfer Pricing Officer was directed to study the impact of the receivables appearing in the accounts of the assessee, looking into why they were shown as receivables and also as to whether the transactions could be characterised as international transactions.  Tribunal also directed the the Assessing Officer to verify and consider the claim of the assessee for credit amounting to Rs. 2,61,461 of tax deducted at source based upon the documents filed in accordance with law.