Held that allowing the appeal, on the bills and invoices itself the assessee had mentioned the credit period on export receivables of the associated and non-associated enterprise. In the case of independent third parties on similar transactions with similar credit periods of similar goods, no interest was charged. This was proved by the assessee for this year by producing the bills of associated enterprises as well as non-associated enterprises. Non-charging of interest on advances being overdue export proceeds from associated enterprises as per internal comparable uncontrolled price method as for similar time on similar conditions, for an almost similar period no interest was charged from non-associated enterprise. The arm’s length price of overdue export proceeds and receivables from associated enterprises was nil. Evidence was not led to show that there was a recession in the business of the assessee in this year or when there was a boom, the assessee was charging interest on such advances. Therefore, the Transfer Pricing Officer/Assessing Officer was to delete the adjustment. (AY.)