Demurrage charges excluded from transfer pricing analysis as extraordinary costs, notional interest on receivables rejected

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....ITAT allowed the assessee's appeal regarding transfer pricing adjustments on two grounds. First, demurrage and detention charges of Rs. 2.57 crores constituted extraordinary costs and were non-operating in nature, given the exponential increase from previous years' charges of Rs. 1.5 lakhs to Rs. 4.05 lakhs on lower turnovers. Excluding these charges brought the operating profit/operating cost ratio to 1.35%, within the arm's length price tolerance limit of 1.78%. Second, no notional interest could be charged on outstanding receivables of Rs. 10.91 crores from local parties transacting on behalf of the associated enterprise, considering the assessee was debt-free and receivables remained unpaid, following established precedent regarding notional interest charges.....