Valuelabs LLP v. ACIT (2020) 80 ITR 19 (SN)(Hyd.)(Trib.)

S. 92C : Transfer pricing-Arm’s length price-Outstanding receivables -Working capital adjustment allowed to assessee-No adjustment called for. [S. 92B]

Tribunal held that no adjustment is to be made on account of notional interest on receivables under Explanation (i), (a) and (c) to section 92B treating the continued debit balance as an international transaction. Moreover when the assessee was a debt free company, and there was no question of charging any interest on receivables. The assessee during the year 2013-14 had not availed of any loan from the associated enterprises or unrelated third parties and was not incurring any interest cost. The agreement between the assessee and its associated enterprise vis-à-vis terms of payment within the stipulated period of 90 days could not form basis for holding the existence of international transaction between the assessee and its associated enterprise where the outstanding was not received within the stipulated period especially where working capital adjustment had been allowed to the assessee. In any case, the credit period of 90 days was less than the credit period of 90 to 120 days of comparables and no adjustment was warranted. (AY. 2013-14)