2021 (10) TMI 751

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....ITAT') in ITA No.7348/DEL/2018 for Assessment Year 2014-2015. 2. The appellant in the present appeal has sought framing of the following questions of law:- 1. Whether the order of ITAT was perverse on fact s directing to exclude Aditya Birla Capital Advisors Pvt. Ltd. as this company performs similar functions as that of the assessee? 2. Whether the order of ITAT was perverse on fact directing to delete adjustments made on account of interest on receivables? 3. Mr.Ruchir Bhatia, learned counsel for the appellant, submits that the ITAT erred in excluding Aditya Birla Capital Advisors Pvt. Ltd, (for short 'ABCL') as a comparable since it is engaged in providing financial advisory services and management services which require procuremen....

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....tion of law, without prejudice to the argument that outstanding receivables are not an "international transaction", learned senior counsel for respondent submits that there were no outstanding receivables itself in the present case. 8. He points out that during the Transfer Pricing Proceedings, the respondent had filed a chart containing details of money received corresponding to invoices raised on AEs. 9. He contends that the Transfer Pricing Officer while making the adjustment on account of the delay in receiving the outstanding has only considered invoices/receivables paid beyond sixty days for making a notional interest adjustment ignoring payments/receivables made in advance. He states that if the adjustment is to be computed for int....