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2022 (2) TMI 70 - AT - Income TaxTransfer pricing adjustment to CSD and ITes segment - HELD THAT:- Both the parties agreed that there is no change in functional profile of the assessee and nature of transactions in the year under consideration as compared to AY 2013-14, therefore following the finding of the Tribunal [2021 (7) TMI 1308 - ITAT DELHI] we set aside the finding of lower authorities and remit the matter back to the Learned AO/TPO for determining arm’s-length price of international transaction of Contract Software Development services (CSD) and ITes in segregated manner complying the direction of the Tribunal in assessment year 2013-14. It is needless to mention that the assessee shall be afforded adequate opportunity of being heard. The grounds No. 3 to 3.9 of the appeal are accordingly allowed for statistical purposes. TP adjustment of interest on receivables - HELD THAT:- The addition in dispute needs to be deleted. However, we find that benchmarking of the main transaction has already been restored to the file of the learned AO/TPO, therefore, we restore this issue of benchmarking of interest on receivables also to the file of the Ld AO/TPO, who shall follow the decision in the case of Kusum Healthcare Private Limited [2015 (4) TMI 180 - ITAT DELHI] and ensure that, if working capital adjustment has been allowed to the assessee, no further addition is required for interest on outstanding receivables. The assessee shall be provided adequate opportunity of being heard on the issue in dispute. The ground Nos. 4 to 4.4 of the appeal are accordingly allowed for statistical purposes.
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