Tribunal held  that fundamentally dissimilar companies were rejected by the Dispute Resolution Panel for other assessment years in the assessee’s case.  That the issue concerning the technical support service fee was remitted to the Transfer Pricing Officer to decide the case on the merits subject to the final outcome of the advance pricing agreement with the Central Board of Direct Taxes. That by the master circular, the Reserve Bank of India prescribed maximum caps on interest on external commercial borrowings with different tenures. The Dispute Resolution Panel is  right in determining the interest rate as LIBOR plus two hundred basis points based on precedent. That the receivables are included under the definition of international transaction consequent to amendments made by the Finance Act, 2012. When the transactional net margin method was considered the most appropriate method, the net margin thereunder would take care of notional interest cost. The Transfer Pricing Officer was directed to consider the working capital adjustment and its impact on the profits of the assessee vis-a-vis its comparables. The upward adjustment on the outstanding receivables was to be deleted. The direction of the Dispute Resolution Panel to consider a notional credit period of thirty days was reasonable. That the assessee did not provide any details as to the reworking charges/reimbursed expenses incurred in relation to export with supporting evidence either before the authorities below or before the Tribunal. The transfer pricing adjustment proposed by the Transfer Pricing Officer in this regard was thus upheld. (AY.2017-18, 2018-19)