S. 92C : Transfer pricing-Arm’s length price-Functionally dissimilar companies cannot be taken as comparable-Outstanding receivable-Debt free company-Adjustment made on interest on receivables not sustainable-Appellate Tribunal-Additional ground admitted-Education cess-Allowable as deduction. [S. 37(1), 40(a)(ii)]
Held that functionally dissimilar companies cannot be taken as comparable. When the assessee is debt free company, adjustment made on interest on receivables is not sustainable. Additional ground admitted and education cess held to be allowable as deduction. (AY.2015-16)