Held that  the Transfer Pricing Officer had re-characterised the trade receivables from associated enterprises as loan given to the associated enterprises and imputed interest on the average trade receivables during the year for a period of 335 days. However in the assessee’s own case for AY 2008-09, the Tribunal had directed the Transfer Pricing Officer to determine the arm’s length price afresh in respect of provision of software development services by reckoning the proper working capital adjustment in the comparable prices and, if the international transaction was found to be at arm’s length, not to make a separate adjustment on account of allowing a credit period for the receivables due from the associated enterprises. The Transfer Pricing Officer was directed to re-do the transfer pricing analysis in respect of interest on outstanding receivables in terms of the Tribunal’s directions. (AY. 2014-15)