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TMI Blog2022 (12) TMI 1203X X X X Extracts X X X X X X X X Extracts X X X X ..... by Ld A.R, the Arm s Length Price of transactions have to be determined by following any one of the methods prescribed under the Income tax Rules. Admittedly, the TPO/DRP, in the instant case, has not followed the same. Accordingly, we deem it proper to restore this issue to the file of AO/TPO for determining the ALP, i.e., interest on delayed receivables by following the rules. The assessee is fr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of interest on delayed receivables. 2. The assessee company renders software development services to its parent company M/s. Verifone Singapore Pte Limited and also to its Associated Enterprise ( A.E. ) M/s. Verifone Malaysia. During the year under consideration, the assessee received payments from it s A.E. for software development services, information technology enabled services and technic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ribed by State Bank of India for computing the interest. According to the direction of Ld. DRP, interest on delayed receivables worked out to Rs.1,91,11,071/-, which was added by the A.O. in the final assessment order. Aggrieved, the assessee has filed this appeal before us. 3. The Ld A.R submitted that the assessee is not disputing the view taken by the AO/TPO that the delayed receivables is a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... have been netted off. Further the TPO has ignored the fact that the assessee did not charge interest on the delayed receivables from non-AEs. The Ld A.R also submitted that interest should have been charged on actual period of delay in excess of the grace period. In view of all these deficiencies, the Ld A.R submitted that this issue requires fresh examination at the end of AO/TPO with liberty to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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