Held, that the corporate guarantee and standby letter of credit were intended to be issued only from April 1, 2011 which fell in the assessment year 2012-13. Hence, guarantee and standby letter of credit were neither intended nor given by the assessee on behalf of the two parties up to March 31, 2011. There was no international transaction at all carried out by the assessee. In any case, only in the event of acquisition of the two overseas entities by the assessee, would they become associated enterprises in the capacity of subsidiaries. The assessee included these transactions of corporate guarantee and standby letter of credit intended to be issued as an international transaction in its transfer pricing study report, only as a matter of abundant caution. In the absence of any international transaction and existence of associated enterprise, there was no requirement of any benchmarking. Hence, the transfer pricing adjustment made is  to be deleted. Held that interest on delayed receivables from associated enterprises would have to be benchmarked separately by the assessee. Once working capital adjustment was granted to the assessee, there was no need for further imputation of interest on outstanding receivables at the end of the year as it would get subsumed in the working capital adjustment. However, the Transfer Pricing Officer had granted a credit period of 70 days to the assessee to recover its dues from its associated enterprises. Hence, in respect of bills raised on or after April 1, 2010 to its associated enterprises, the Transfer Pricing Officer was to consider the date of realisation and whether they had been realised within the credit period allowed of 70 days, and in respect of outstanding bills as on April 1, 2010 (i. e., opening balance) from these associated enterprises, the date of realisation thereof. If the bills were realised beyond the granted credit period of 70 days, interest was to be imputed on those bills and interest is  to recomputed on outstanding receivables. Held that the issues regarding brought forward loss not allowed to be set off and full credit for advance tax not being given while computing the tax liability, required factual verification and, therefore were remanded to the Assessing Officer for de novo adjudication in accordance with law.That the Assessing Officer has  to charge interest under section 234D , if any, in accordance with law  That the Assessing Officer is  to grant interest under section 244A in accordance with law, if, ultimately, the order giving effect resulted in refund.(AY. 2011-12, 2012-13)