Assessee received certain amount on account of Interest on receivables wherein Credit agreed between assessee and it AEs was 30 days.  TPO pointed out that working capital adjustment was already made and therefore, no addition should be made on account of interest on receivables because it was not an independent transaction and it should be considered together as per rule 10A(d).  Tribunal held that extra credit allowed could be considered as an independent international transaction and same be compared with internal CUP being average cost of total funds available to assessee and directed TPO to find out cost of total funds available to assessee and same were to be adopted as internal CUP for benchmarking of this independent international transaction i.e. allowing extra credit in addition to agreed credit period of 30 days.High Court upheld order of Tribunal.  On SLP, revenue submitted that this appeal had to be dismissed on ground of low tax effect as being covered by Circular No. 17 of 2019 dated 8-8-2019 issued by Department of Revenue, Ministry of Finance. Low tax effect SLP of Revenue is dismissed. Question of law is kept open.  (AY. 2012-13)