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2016 (1) TMI 1117 - ITAT DELHI

2016 (1) TMI 1117 - ITAT DELHI - TMI - Transfer pricing adjustment - selection of comparables - Held that:- The conceptualization of the services is primarily done by Ameriprise US which collects data and sends the same in raw form to the assessee or the other relevant data is procured by the assessee directly from the sources referred by the Ameriprise US. The assessee compiles such raw data in desired format/sequence and undertakes processes, such as, merging of data, sequencing, etc. This is .....

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that there was acquisition by this company of McCamish Systems LLC. Acquisition of McCamish Systems LLC during the year, being an extraordinary financial event, renders it incomparable. Following the reasons taken note of above, we order for the elimination of this company from the final set of comparables. - TCS E-Serve International Ltd. and TCS e-Serve Ltd.the entity level figures render this company as unfit for comparison. Therefore, we order for the removal of this company from the fi .....

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the list of comparables with the adjusted data for the relevant financial year itself. Respectfully following the reasoning of Coordinate Bench in immediately preceding year, we set aside the impugned order and remit the matter to the file of TPO/AO for examining this aspect of the matter. - CG-VAK Software and Exports Ltd. (Seg.) - at a company cannot be excluded from the list of comparables on the ground of its low turnover. In principle, we direct the inclusion of the relevant segment of .....

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, ACCOUNTANT MEMBER For The Appellant : Sh. Harpreet Singh, Advocate and Ms Ananya Kapoor, Advocate For The Respondent : Sh. Amrendra Kumar, CIT/DR ORDER Per L.P. Sahu, Accountant Member: This appeal, at the instance of assessee, emanates from final assessment order dated 14.11.2014 under section 143(3) read with section 144C of the Income Tax Act, 1961 ( the Act ) in pursuance to the directions of Disputes Resolution Panel (DRP) dated 10.10.2014 for the assessment year 2010-11. The assessee has .....

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is referred to separately, which may kindly be considered independent of each other. That, on the facts and circumstances of the case and in law: 1. The learned TPO / AO / DRP have erred in making an addition of INR 82,093,645 to the total income of the Appellant in respect of international transactions pertaining to provision of IT-enabled back-office services by the Appellant to its Associated Enterprises ( AEs ) and imputed interest on outstanding inter-company receivables arising therefrom ( .....

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es (a) to (d) of sub-section (3) of section 92C of the Act. 3. The learned TPO / AO / DRP have erred in: a. Not accepting the use of multiple year data, as adopted by the Appellant in its Transfer Pricing ( TP ) documentation; and b. Determining the arm s length margins / prices using data pertaining only to financial Year ( FY ) 2009-10 which was not available to the Appellant at the time of complying with the Indian TP documentation requirements. 4. The learned TPO / AO / DRP have erred in rej .....

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to cherry picking of comparables to determine ALP. 6. The learned TPO / AO have erred in arbitrarily including Genesys International Corporation Limited and Omega Healthcare Limited in the list of final comparables when the same were not considered as comparable in the assessment order passed by learned TPO under section 92CA(3) of the Act. 7. learned TPO / AO / DRP have erred in passing an order which has computational errors in the margin of comparable companies used in determination of arm s .....

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ave erred in not making suitable adjustments to account for differences in the risk profile of the Appellant vis-à-vis the comparable companies. 12. learned TPO / AO / DRP have erred in holding inter-company receivables arising from the international transaction pertaining to provision of IT-enabled back office services to constitute a separate international transaction and proceeding to benchmark the same by application of Comparable Uncontrolled Price ( CUP ) method. 13. learned AO has .....

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S is to provide services towards financial planning and other areas like institutional asset management and advisory, pension fund management, the management and administration of certain plans. The assessee was incorporated in August, 2005 and started operations in October, 2005. It is engaged in providing Information Technology (IT) enabled services to Ameriprise US. The assessee reported two international transactions, including remuneration from the Provision of IT-enabled back office servic .....

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own that their arithmetic mean of operating profits compared favourably with assessee s profit rate and, hence, the international transaction of Provision of IT enabled back office services was at arm s length price (ALP). On a reference made by the AO for determining the ALP of the international transactions, the TPO treated only five companies as comparable from the assessee s list. He added eight new companies, thereby making a total of thirteen companies, considered as comparable, as under : .....

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sed before us is against the inclusion/exclusion of certain companies in/from the list of comparables. In this regard, the assessee is aggrieved against the inclusion of the following six companies, viz., i. Accentia Technologies Ltd; ii. iGate Global Solutions Ltd. iii. Infosys BPO Ltd. iv. TCS E-Serve International Ltd. v. TCS E-Serve Ltd. and vi. eClerx Services Ltd. 3. The assessee is also aggrieved against the non-inclusion of (i) CG Vak Software & Exports Ltd., and (ii) R. Systems Inte .....

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nting, Sales and use tech support. Under this category, the assessee provides services to Ameriprise US in the nature of Credit purchasing cards, Bank reconciliation, Inter-company reconciliations, Maintenance of fixed asset registers and Payroll, etc. The second category is Financial planning services , which refers to the assessee providing support in client data entry for assistance in preparation of draft reports for customers. The third broad category is General counsel office services, whi .....

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review the performance of various products offered to its customers and other related activities. The next broad category is Vendor management services which means performing data processing services in respect of call centres and back office operations of certain companies, outsourced by Ameriprise US. The assessee is required to convert the data into presentable form to enable Ameriprise, US to evaluate the performance of its outsourced call centres and back office operations. Next category is .....

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of the services is primarily done by Ameriprise US which collects data and sends the same in raw form to the assessee or the other relevant data is procured by the assessee directly from the sources referred by the Ameriprise US. The assessee compiles such raw data in desired format/sequence and undertakes processes, such as, merging of data, sequencing, etc. This is an in-house function performed by the assessee for further actions to be taken by Ameriprise US. 6. At this juncture, we deem it e .....

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d Offices, the specified products and services as follows: 3.1 AIPL shall process the raw data received/sourced from or on directions of Ameriprise USA and, as applicable, its Designated Offices. 3.2 AIPL shall present the customized/processed data in the form of reports/graphs/diagrams as the final output. 3.3 AIPL shall use the IT infrastructure in the form of computers, leased lines, etc., to process/customize the data and supply it to Ameriprise USA and, as applicable, its Designated Offices .....

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or rendering of outsourced call centre and back office services. This would include: 3.5.1 Collection of data on performance of back office operations in India; 3.5.2 Analyse, evaluate and process such data into specified formats by applying information technology tools and provide suitable observations thereof. 3.6 To the extent necessary or desirable, the Parties shall be free to add one or more schedules to this Agreement to describe in greater detail the Specified Products and Services. 7. A .....

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rt services to Ameriprise US without any direct involvement in the conduct of business of Ameriprise US. With the above background of the assessee s nature of work done for its AE, which is primarily in the nature of rendering IT enabled services, which position has also been admitted by the TPO as well, we proceed to determine the comparability or otherwise of the companies challenged before us. A. Challenge to the inclusion of companies 8 Accentia Technologies Ltd. 8.1 The assessee objected to .....

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se India Pvt. Ltd. vs. ACIT) for the reason that apart from ITES, the company also generates revenue from software products and segmental figures are not available. (pg. 15, 16 of the order) Also, recently rejected as a comparable in Techbooks International Pvt. Ltd. (ITA No. 240/Del/2015 for AY 2010-11) (pg. 18 and 19 of the orderyear of amalgamation-extraordinary financial event). Moreover, applying the Hon ble Delhi High Court judgment in the case of Rampgreen Solutions vs. CIT (ITA No. 102/2 .....

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port of this company, a copy of which has been placed in the paper book. Notes to Accounts of this company, indicate about the amalgamation of Asscent Infoserve Pvt. Ltd. with it as approved by the shareholders in the court convened meeting held on 25.4.2009 and, subsequently, sanctioned by the Hon ble High Court on 21.8.2009. The Mumbai Bench of the Tribunal in Petro Araldite (P) Ltd. Vs. DCIT (2013) 154 TTJ (Mum) 176, has held that a company cannot be considered as comparable because of except .....

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mpany cannot be considered as comparable due to this extra-ordinary financial event. Accordingly, the same is directed to be excluded from the final list of comparables. 9. i-Gate Global Solutions Sdn. Bhd. 9.1 The assessee objected to the inclusion of this company in the list of comparables on the ground of company offering both IT and ITES services, viz. there being insufficient segmental information and also on the ground of peculiar circumstance of amalgamation of i-Gate Global Solutions Sdn .....

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members of the company on 12.8.2009 and subsequently sanctioned by the Hon ble High Court by its order dated 24.2.2010. As the financial results of this company also include the results of amalgamating company, in our considered opinion, this is an extraordinary financial event, which renders it unfit for comparison with the assessee company. While discussing the comparability of Accentia Technologies Ltd. (supra), we have referred to certain decisions in which it has been held that a company lo .....

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y large scale of operations (pg. 242, 243 of PB-2) 2) Exceptional year of operations (acquisitions- pg. 213 of PB-2) 3) High brand value and intangibles (increase in goodwill- pg. 235 of PB- 2)Recently rejected as a comparable in Techbooks International Pvt. Ltd. (ITA No. 240/Del/2015) (AY 2010-11) for the same reasons (pg. 29 of the order- exceptional year of operations-acquisition of McCamish Ltd.) 10.2 After considering the rival submissions and perusing the relevant material on record, we fi .....

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over and profits, as this is the second year of operations of the Company and first full-year as a step down subsidiary of TCS. It was also agitated that Company is functionally dissimilar and there are insufficient segmental information. The TPO noticed that this company was also offering ITES. He did not treat high turnover of this company as a relevant factor in considering the comparability. Eventually, this company was included in the final set of comparables. 11.2 We have heard the rival s .....

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orporate and retail clients. Technical services involve software testing, verification and validation of software at the time of implementation and data centre management activities. It is manifest that this company is engaged in rendering BPO services to the banking and financial services industry (BFSI) and Travel, Tourism and Hospitality (TTH). It is providing services to BFSI and TTH and such services include Transaction processing and Technical services . In other words, the remuneration of .....

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this company are in the nature of servicing and maintenance of software. At this stage, it is relevant to note that a company providing software services may be of two types, viz., a company providing software development services and a company providing software services other than software development services (hereinafter also called a company providing non-development software services ). 11.3 At this juncture we are inclined to quote view taken by the Delhi Bench of Tribunal in Techbook Int .....

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for obtaining the desired results, is called a company providing non-development software services. Thus, it is crystal clear that there is a phenomenal difference between a company providing software development services and a company providing software non-development services in terms of expertise, professional qualification and experience required for rendering such services. A company providing software non-development services performs a relatively low-end service. Thus the line of distin .....

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software. From the above discussion, it is overt that a company providing software development services is distinct from and incomparable with a company providing non-development software services. 11.4 We find that the assessee is a company providing non-development software services, in the nature of conversion of data from hard copy or files into electronic format. The assessee is not providing any software development services to its AE. On the other hand, this company is also providing Tec .....

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chnical services (which are in the nature of software development, absent in the assessee s case). In the absence of the availability of any such segregation of the total revenue of this company, it is not possible to separately consider its profitability from rendering of Transaction processing services . As such, the entity level figures render this company as unfit for comparison. Therefore, we order for the removal of this company from the final set of comparables. 12. TCS e-Serve Ltd. 12.1 .....

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port of this company is available on page 398 of the paper book. Ld. Counsel for the Assessee submitted that like TCS eServe International Limited, this Company is also engaged in providing Transaction processing and Technical services . By referring to Profit & Loss Account in standalone financials of the Company it was pointed out that during the relevant financial year, the Company has received Income of ₹ 1,35,94,110/- from Transaction Processing and Other Services. On referring to .....

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ayments in relation to the services offered by Citigroup to its corporate and retail clients. Technical services involve software testing, verification and validation of software at the time of implementation and data centre management activities. 12.3 We also note that Segmental Information given in Point No. 8 of Schedule O - Notes to Accounts in standalone financials of the annual report shows that Company is engaged in Business Process Outsourcing (transaction processing) services to the Ban .....

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vertical ( i.e. industry vertical) to help its customers achieve their business objectives by providing innovative best-in-class services. We find that this company is also providing ITES. Unlike TCS e- Serve International Ltd., this company is not providing any technical services involving software testing, verification and validation of software etc. Since the functional profile of this company on a broader basis is no different from that of the assessee, both being involved in rendering ITES .....

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rvices provided by this company, being the ITES, which is similar to that of those rendered by the assessee, again the ITES, we cannot order its exclusion simply for the reason that the verticals of ITES are somewhat different. If one goes to make a comparison in the way suggested by the ld. AR under the TNMM, then it will be very difficult, if not impossible, to find out a ditto comparable. A company which satisfies the broader parameters of comparability in the overall same segment, cannot be .....

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nternational P. Ltd. (supra). On perusal of Schedule O - Notes to Accounts of the Standalone financials of the Company, it is clear that the Company is engaged in transaction processing and technical services activities. No separate segmental details are available. On a careful reading of the decision of coordinate Bench in Techbook International P. Ltd. (supra) it is clear that Schedule O - Notes to Accounts in respect to carried out by Company and relevant segmental details were never brought .....

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s. 13. eClerx Services Limited 13.1 The assessee objected to the inclusion of this comparable on following points - Reasons for rejection- 1) Significant intangible assets (pg. 137, 144 of PB-1) 2) Insufficient Segmental details (Financials-pg. 134 and pg. 144 of PB-1) This comparable has been rejected recently by the Hon ble ITAT, in Assessee s own case for AY 2009-10 (ITA No. 2010/Del/2014- Ameriprise India Pvt. Ltd. vs. ACIT) for the reason that it is a KPO providing data analytics and data p .....

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Bench) for the same reasons. Recently, the Hon ble Delhi High Court, in the case of Rampgreen Solutions vs. CIT (ITA No. 102/2015) has held that this comparable is a KPO and is functionally different from other BPO service providers. It relied on the aforementioned Special Bench decision and held that this company is engaged in data analytics, data processing services, pricing analytics, bundling optimization, content operation, sales and marketing support, product data management, revenue mana .....

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essment Year 2009-10) (ITA no. 2010/Del/2014 & 2575/Del/2014, order dated 14.08.2015) and ratio laid down by jurisdictional High Court in the case of Rampgreen Solutions (supra), we direct the exclusion of this comparable from the final list of comparables. B. Challenge to the exclusion of companies 14. R. Systems (Seg.) 14.1 The TPO eliminated R. Systems (Seg.) on the ground that it was following different year ending, namely, 31st December and, hence, was not comparable. The ld. AR fairly .....

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hence such companies were rightly excluded. 14.2. After considering the rival submissions and perusing the relevant material, it is noticed that the assessee company is having financial year ending covering the period 1.4.2009 to 31.3.2010. In that view of the matter, a valid comparison can be made only if the comparable companies too have the same financial year. In this regard, we consider it appropriate to note the relevant part of sub-rule (4) of Rule 10B which provides that: the data to be .....

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, then, the comparables must also have the data relating to the financial year ending 31st March itself. If such a data is not available, then, a company albeit comparable, also disqualifies. Espousing the facts of the instant case, we find that insofar as the functional comparability of this Company is concerned, the TPO has not disputed the same. The only reason given for its exclusion is the non-availability of data for the relevant financial year. The ld. AR contended that though the year en .....

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nt data for the concerned financial year can be deduced from the information available from their annual reports, then, there can be no objection to the inclusion of these companies in the list of comparables with the adjusted data for the relevant financial year itself. Respectfully following the reasoning of Coordinate Bench in immediately preceding year, we set aside the impugned order and remit the matter to the file of TPO/AO for examining this aspect of the matter. 15. CG-VAK Software and .....

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e functional similarity of the relevant segment of this company. In such circumstances, the question arises as to whether the relevant segment of this company can be excluded from the list of comparables merely on the ground that the revenue from this segment is only ₹ 83 lacs? In our considered opinion, the quantum of turnover can be no reason for the exclusion of a company which is otherwise comparable. We find that Hon ble jurisdictional High Court in the case of ChrysCapital Investment .....

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s. The TPO is directed to include the operating profit/operating costs of the ITES segment of this company in the list of comparables, after due verification of the necessary figures for determination of the operating profit margin etc. 16. Treatment of Foreign Exchange Fluctuation 16.1. The next issue taken up before us is against treating foreign exchange difference as non-operating as against the assessee s treatment of operating cost. On a pertinent query, it was stated by the ld. AR that th .....

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of the comparables. When we advert to the nature of such foreign exchange gain earned by the assessee, it has also been admitted by the ld. DR that the same is in relation to the trading items emanating from the international transactions. When the foreign exchange loss directly results from the trading items, we fail to appreciate as to how such foreign exchange fluctuation loss can be considered as non-operating. 16.3. The Special Bench of the Tribunal in ACIT Vs Prakash I. Shah (2008) 115 ITD .....

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erted into Indian rupees, the entire amount is relatable to the exports. In fact, it is only the translation of invoice value from the foreign currency to the Indian rupees. The Special bench held that the exchange rate gain or loss cannot have a different character from the transaction to which it pertains. The Bench found fallacy in the submission made on behalf of the Revenue that the exchange rate difference should be detached from the exports and be considered as an independent transaction. .....

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(P) Ltd. Vs DCIT (2011) 47 SOT 45 (URO) (Bangalore). The Mumbai Bench of the Tribunal in S. Narendra Vs Addtl. CIT (2013) 32 taxman.com 196 has also laid down to this extent. In view of the foregoing discussion and respectfully following the view taken by Coordinate Bench in immediately preceding year, we are of the considered opinion that the amount of foreign exchange gain/loss arising out of revenue transactions is required to be considered as an item of operating revenue/cost, both of the a .....

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ings. 17. Inter-company Receivables 17.1 Briefly stated, the factual matrix concerning this ground is that the assessee had shown certain receivables from its AE. On examination of the assessee s balance sheet, it was noticed by the TPO that payments against the invoices raised by the assessee were not received within the stipulated time as provided in the Agreement. On being called upon to furnish the time period for payment as per Service agreement and why the delayed payments be not treated a .....

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s as chargeable to interest, he proposed TP adjustment of ₹ 41,039/-. The DRP has discussed this aspect on page 46 of its direction. It was held that since, normal business practice requires payment of dues beyond a reasonable period, the TPO was justified to charge interest beyond the Arm s length period. Any delay beyond a period of 30 days, in an arm s length situation would have warranted a return base on opportunity cost of the money. Accordingly, DRP upheld that any delay beyond the .....

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amounts to an international transaction and the ALP of such an international transaction is required to be determined. 26. Now, we come to the computation of the ALP of the international transaction of debt arising during the course of business. The TPO has calculated TP adjustment on account of interest on outstanding debts beyond a period of 30 days by noting the number of days after which the relevant invoice was realized. From this Table given on page 83 of the TPO s order, it can be seen t .....

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all be made on the basis of the invoices raised by AIPL and shall be cleared within thirty days from the date of the invoice. Under no circumstances shall the payment be delayed for more than sixty days from the date of the invoice. Any revision to the credit period may be agreed by parties by exchanging e-mails or other forms of correspondence without requiring any change or modification to this Agreement. 27. Above para of the Agreement divulges that all the payments are required to be made by .....

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e have noticed above that all the invoices stood realized within a period of 60 days, there can be no question of charging any interest as a separate transfer pricing adjustment. 28. We do not approve the reasoning given by the DRP about the subsuming of such interest in the working capital adjustment. It is axiomatic that the working capital adjustment is in respect of international transaction of rendering services to the AE. Interest for the credit period allowed as per the Agreement is facto .....

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lated period is a separate international transaction. Allowing working capital adjustment in the international transaction of rendering services can have no impact on the determination of ALP of the international transaction of interest on receivables from AEs beyond the stipulated period allowed as per the Agreement. The amendment made by the Finance Act, 2012 in terms of insertion of Explanation to section 92B with retrospective effect from 1.4.2002 by considering any other debt arising during .....

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price charged for rendering services by impliedly including the interest for the period allowed for realization of invoices as per the terms of the agreement, the international transaction of charging interest on late recovery of trade receivable covers the period which starts with the termination of the period of credit allowed under the agreement, which is subject matter of the international transaction of rendering of services. There is one more fallacy in the reasoning given by the DRP abou .....

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ised on 1st May; period allowed for realization is two months; and the invoice is actually realized on 31st December. Notwithstanding the fact that interest on such late realization would become chargeable for a period of 6 months (from 1July to 31December), but the amount of invoice will not be receivable as at the end of the financial year on 31st March. As such, this receivable would not have an impact on the working capital adjustment in any manner, but would call for addition on account of .....

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