Tribunal held that the transfer pricing adjustment on account of interest for the entire period of delay beyond 60 days could not be treated as a separate international transaction of trading debt arising during the course of business. When the interest for realisation of trade advances up to 150 days was part and parcel of the price charged from the associated enterprise, the delay up to this extent could not give rise to a separate international transaction of interest uncharged. The effect of delay on interest up to 150 days over and above the normal period of realisation in an uncontrolled situation, should be considered in the determination of the arm’s length price of the international transaction of provision of information technology enabled data conversion services and the period of delay above 150 days should be considered as a separate international transaction in terms of clause (c) of Explanation to section 92B. It is the currency in which the loan is to be repaid which determines the rate of interest and hence the prime lending rate should not be considered for determining the interest rate. The assessee could not show the difference between the working capital of the assessee and that of the comparable companies. Thus, the adjustment of working capital was not at all there in the case of the assessee for this year. (AY. 2012-13)