9911796707
TMI Blog2018 (4) TMI 926X X X X Extracts X X X X X X X X Extracts X X X X ..... e delay is more that 300 days. If there are similar nature of transaction with comparable uncontrolled transactions and also with related parties, then there is an internal CUP to bench mark the controlled transaction with comparable uncontrolled transaction. Under CUP price charged or paid for the services provided in a comparable uncontrolled transaction is taken into consideration and it is the adjusted price paid for availing services which constitutes the benchmark for comparison with the price paid for availing of any services in an international transaction. If there are similar transactions of services with related parties as well as unrelated parties and the price charged or paid are comparable, then it is taken to be at arm’s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... turn is held by Genpact Ltd. Bermuda . The assessee is engaged in the business of providing risk consulting, advisory and risk assurance solutions. The company s services are in the nature of risk assurance, business improvement, business risk assessment, corporate governance, business system controls, enterprise risk management, cost management solutions etc. It serves ITES, BOP telecom, travel, hospitality, manufacturing, biosciences, retail and consumer products, and financial services industries. In a nutshell it can be said that the company operates as an information technology enabled consultancy solutions provider rendering integrated risk and technology solutions in India and internationally. 4. The only disputed transaction bef ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is an internal CUP for benchmarking the transactions, i.e., both for the controlled and uncontrolled transactions assessee has not been charging interest, and therefore, no adjustment should be made. In support, he has given the following tabulation showing that no interest has been charged from AEs and non AEs. Tabulation showing no interest charged from AE/Non AE Particulars AEs (NR)(in INR) AES (Domestic in INR) Non-AEs (in INR) Total (in INR) Revenue from consultancy services 10,41,30,757 70,23,200 12,73,70,180 23,85,24,137 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ther cases. 8. After considering the rival submissions and on perusal of the relevant findings and material placed on record, the only dispute before us is with regard to the adjustment by way of imputing interest @ 17.22% by the TPO on account of receivables from the AE. Here in this case, it is an undisputed fact that the assessee has also rendered similar services to non AEs/unrelated parties and on receivables from the non AEs also, there have been delays on receivables on which no interest has been charged by the assessee. Before us, invoice wise details have been furnished highlighting the details of amount of the invoice date; date of receipt and the number of outstanding days for the payment has been given. From such details, it ..... X X X X Extracts X X X X X X X X Extracts X X X X
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