Dismissing the appeal of the revenue the Court held that the Tribunal is justified in directing for exclusion of ABCL from the list of comparables. Court also held that there can be no notional computation of delayed receivables’ only ignoring the receivables received in advance. Appeal was dismissed. Question as to whether in a given case transfer pricing adjustment on delayed receivable could apply even to a debt-free company or not, does not arise on facts and is left open Followed Mckinsey Knowledge Centre India (P) Ltd v .PCIT ( 2018) 407 ITR 450 ( Delhi) (HC) .(AY. 2014-15)
PCIT v. Mckinsey Knowledge Centre India (P) Ltd. (2021) 323 CTR 360 / 207 DTR 60/( 2022) 284 Taxman 484 (Delhi)(HC)Editorial : Notice issued in SLP filed by Revenue , PCIT v. Mckinsey Knowledge Centre India (P) Ltd. (2022) 288 Taxman 640 (SC).
S. 92C : Transfer pricing-Arm’s length price-Functionally different-Justified in directing for exclusion of ABCL from the list of comparables-Interest receivable-Notional interest for relating to alleged delayed in collecting receivable-No substantial question of law-Question as to whether in a given case transfer pricing adjustment on delayed receivable could apply even to a debt-free company or not. does not arise on facts and is left open. [S. 260A]