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TMI Blog2023 (4) TMI 58X X X X Extracts X X X X X X X X Extracts X X X X ..... LORE] has considered exclusion of companies on the ground that related party transactions are more than 15% and has also held that the RPT filter is to be considered on the upper threshold limit of 15% by relying on the decision of the Hon'ble Karnataka High Court in the case of PCIT and Anr. Vs. M.s YODLEE INFOTECH PVT LTD. [ 2018 (6) TMI 1783 - KARNATAKA HIGH COURT] Thus we remit the issue back to the TPO with a direction to verify the RPT transaction of Rheal Software Pvt Ltd and decide the comparability of the company considering the decision above. Exclusion of CG VAK Software and Exports Ltd. - We notice that the coordinate bench of the Tribunal in the case of 3DPLM [ 2014 (12) TMI 612 - ITAT BANGALORE] has held that in the absence of segmental information or details the companies cannot be taken for comparable analysis. As noticed that the assessee has not contended the exclusion of this company before the TPO/DRP - we remit the issue back to the TPO/AO with a direction to consider the issue of exclusion of C G VAK Software and Exports Ltd., afresh. Inclusion of I2T2 India Limited rejected stating that the company fails the turnover filter - We notice that in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... resident and Ms. Padmavathy S., Accountant Member For the Assessee : Shri Padamchand Kincha, CA For the Revenue : Shri Manjunath Karkihalli, CIT-DR ORDER Per: Padmavathy, A.M. This appeal is against the final assessment order passed by National e-assessment centre dated 22.04.2021 passed under Section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (the Act) for the assessment year (AY) 2016-17. 2. The assessee raised the following concise grounds of appeal: General Grounds 1. The orders passed by the learned Deputy Commissioner of Income-tax Transfer Pricing - 2(1)(1) (Transfer Pricing Officer/ TPO); and Honorable Dispute Resolution Panel [collectively referred as lower income tax authorities for brevity] to the extent prejudicial to the assessee are bad in law and liable to be quashed. 2. The learned AO erred in not passing the order in conformity with the procedure prescribed in faceless assessment scheme under section 144B of the Act. 3. The learned AO has erred in making an addition of Rs. 5,18,74,725 to the total income of the Appellant, without appreciating that the learned TPO vide order dated 16.04.2021 had redu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the arms-length price in connection with the impugned international transactions by: (a) not providing cogent reasons for such rejection; and (b) carrying out fresh economic analysis which is noncontemporaneous and not in accordance with Rule 108(4). 10. The lower income tax authorities have erred in including the following companies, even though they fail the higher threshold limit of INR 200 crores for turnover filter: (a) Infosys Ltd. (b) Larsen Toubro Infotech Ltd (c) Persistent Systems Ltd (d) Aspire Systems (India) Pvt Ltd (e) Thirdware Solution Ltd. (f) Cybage Software Pvt Ltd. (g) Nihilent Ltd. 11. The lower income tax authorities have erred in including the operating income and operating expense of FY 2014-15 and FY 2013-14 in computing the weighted average margin for R S Software Ltd even though the same fails the upper turnover limit of Rs. 200 crores for the above-mentioned years. 12. The lower income tax authorities have erred in law and in facts, by accepting the following companies as comparable even though the same did not fulfil one or more filters applied by the learned TPO or were not c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... panies whose data for FY 2015-16 was available; (d) rejecting the methodology/workings provided by the Appellant for computing the risk adjustment without providing any cogent reasons. (e) not allowing appropriate adjustments under Rule 10B to account for, inter alia, differences in (i) accounting practice; (ii) positive working capital adjustment; (iii) risk profile between the Appellant and the comparable companies, if favourable to the Appellant. 18. On facts and circumstances of the case and in law applicable, the aforesaid companies should be included/ rejected as comparable companies. Interest on delayed receivables 19. The lower income tax authorities erred in making the notional interest adjustment with respect to outstanding receivables of the Appellant for FY 2015-16. 20. The lower income tax authorities erred in making the notional interest adjustment with respect to outstanding receivables of the appellant for FY 2015-16. The Learned TPO erred in (a) Re-characterisation of the net outstanding receivables as on 31st March 2016 as a deemed loan and benchmarking the same is not permissible in law. (b) Not appreciating that th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... evel indicated in TNMM analysis. For the purpose of TP study the assessee has computed the profit margins for each of the segments i.e. Transactions with AEs, Non-AEs, and Indian AEs and this segmental profitability statement were certified by an Independent Chartered Accountant. The financials of the assessee with its AE as per the TP study are as under: - Particulars Amount in Rs. Revenue from operations 18,66,58,660 Unbilled Revenue 1,06,98,655 Total Operating Revenue 19,73,57,315 Employee Benefit Expenses 12,97,72,926 Depreciation and Amortization Expenses 11,84,149 Other Expenses 2,61,48,809 Total expenses 15,71,05,884 Total Operating Profit 4,02,51,431 Operating Margin on Operating Cost 25.62% 5. The TPO rejected the segmental profitability statement on the ground that adoption of head cou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt Ltd 15.94% 29.19% 35.72% 26.36% 9 Inteq Software Pvt. Ltd 7.53% 32.14% 45.00% 28.20% 10 Persistent Systems Ltd. 26.92% 31.34% 35.64% 30.89% 11 Infobeans Technologies Ltd. 34.98% 20.78% 41.95% 32.42% 12 Thirdware Solution Ltd. 23.89% 44.39% 44.68% 36.90% 13 Infosys Ltd. 38.22% 41.30% 36.28% 38.61% 14 Aspire Systems (India) Pvt. Ltd 34.26% 47.56% 38.04% 39.28% 15 Cybage Software Pvt Ltd 62.90% 68.68% 68.82% 66.45% No of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . The TPO based on the directions of the DRP recomputed the TP adjustment in software segment as Rs.4,66,55,698 and interest on delayed receivable as Rs.28,18,152. In the final assessment order however the TP adjustment is retained as in the draft assessment order. In the detailed grounds of appeal raised by the assessee, the ground pertaining to the AO retaining the addition made towards TP adjustment as in draft assessment in the final assessment order was contended vide Ground 4.2. However during the course of hearing, the ld AR did not press this ground and proceeded to argue on merits relating to the TP adjustment contended through the concise grounds reproduced above. We therefore dismiss ground no. 4.2 as not pressed and proceed to adjudicate only the issue raised in the concise grounds in the following paras. Out of the concise grounds the ld AR argued only the following during the course of hearing and therefore the rest of the grounds are dismissed as not pressed (i) Computing the entity level margin ignoring the segmental margin computed by the assessee Ground 7 (ii) Exclusion of companies based on turnover filter Ground 10 (iii) Exclusion of margins ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ftware (India) Ltd., on the ground that the related party transaction is more than 15%; or in the alternative prayer for excluding the operating income and operating expense of FY 2014-15 and FY 2013-14 in computing the weighted average margin for RS Software Ltd, even though the same fails the upper turnover limit of Rs. 200 crores for the above-mentioned years. (iii) non acceptance of Assessee's claim regarding non inclusion of certain companies comparable company. Inteq Software Pvt.Ltd., and Infobeans Software Ltd. 8. As far as Ground No. 8.7 is concerned, the relevant provisions of the Act in so far as comparability of international transaction with a transaction of similar nature entered into between unrelated parties, provides as follows: 10B . Determination of arm's length price under section 92C. (1) For the purposes of sub-section (2) of section 92C, the arm's length price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely : (a) to (d) .. (e)transactional net margin method, by whi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... onomic development and level of competition and whether the markets are wholesale or retail. (3) An uncontrolled transaction shall be comparable to an international transaction [or a specified domestic transaction] if (i) none of the differences, if any, between the transactions being compared, or between the enterprises entering into such transactions are likely to materially affect the price or cost charged or paid in, or the profit arising from, such transactions in the open market; or (ii) reasonably accurate adjustments can be made to eliminate the material effects of such differences. 9. A reading of rule 10B(1)(e)(iii) of the Rules read with sec.92CA of the Act, would clearly shows that the net profit margin arising in comparable uncontrolled transactions has to be adjusted to take into account the differences, if any, between the international transaction and the comparable uncontrolled transactions, which could materially affect the amount of net profit margin in the open market. 10. Chapters I and III of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (hereafter the TPG ) contain extensive guidance ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t of such high turnover on the margin should be seen. The DRP therefore held that a company which is otherwise functionally comparable cannot be excluded only on the basis of high turnover. The Assessee has raised Grd.No.4 before the Tribunal challenging the aforesaid view of the DRP. 12. On the issue of application of turnover filter, we have heard the rival submissions. The parties relied on several decisions rendered on the above issue by the various decisions of the ITAT Bangalore Benches in favour of the Assessee and in favour of the Revenue, respectively. The ITAT Bangalore Bench in the case of Dell International Services India (P) Ltd. Vs. DCIT (2018) 89 Taxmann.com 44 (Bang-Trib) order dated 13.10.2017, took note of the decision of the ITAT Bangalore Bench in the case of Sysarris Software Pvt.Ltd. Vs. DCIT (2016) 67 Taxmann.com 243 (Bangalore-Trib) wherein the Tribunal after noticing the decision of the Hon ble Delhi High Court in the case of Chryscapital (supra) and the decision to the contrary in the case of CIT Vs. Pentair Water India Pvt.Ltd., Tax Appeal No.18 of 2015 dated 16.9.2015 wherein it was held that high turnover is a ground to exclude a company from the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... turnover of 8.15 crores, the companies which also have turnover of 1.00 to 200.00 crores only should be taken into consideration for the purpose of making TP study. 42. The Assessee s turnover was around Rs.110 Crores. Therefore the action of the CIT(A) in directing TPO to exclude companies having turnover of more than Rs.200 crores as not comparable with the Assessee was justified. As rightly pointed out by the learned counsel for the Assessee, there are two views expressed by two Hon ble High Courts of Bombay and Delhi and both are nonjurisdictional High Courts. The view expressed by the Bombay High Court is in favour of the Assessee and therefore following the said view, the action of the CIT(A) excluding companies with turnover of above Rs.200 crores from the list of comparable companies is held to correct and such action does not call for any interference. 13. The Tribunal in the case of Autodesk India Pvt.Ltd. Vs. DCIT (2018) 96 Taxmann.com 263 (Bangalore-Tribunal), took note of all the conflicting decision on the issue and rendered its decision and in paragraph 17.7. of the decision held as that high turnover is a ground for excluding companies as not comparab ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... companies on the basis of turnover in Transfer Pricing cases. The decision was rendered as early as 5.8.2011. The decisions rendered by the ITAT Mumbai Benches cited by the learned DR before us in the case of Willis Processing Services (supra) and Capegemini India Pvt.Ltd. (supra) are to be regarded as per incurium as these decisions ignore a binding co-ordinate bench decision. In this regard the decisions referred to by the learned counsel for the Assessee supports the plea of the learned counsel for the Assessee. The decisions rendered in the case of M/S.NTT Data (supra), Societe Generale Global Solutions (supra) and LSI Technologies (supra) were rendered later in point of time. Those decisions follow the ratio laid down in Willis Processing Services (supra) and have to be regarded as per incurium. These three decisions also place reliance on the decision of the Hon ble Delhi High Court in the case of Chriscapital Investment (supra). We have already held that the decision rendered in the case of Chriscapital Investment (supra) is obiter dicta and that the ratio decidendi laid down by the Hon ble Bombay High Court in the case of Pentair (supra) which is favourable to the Assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be ignored because they fail the test of comparability in those two earlier years by reason of the application of the Rs.200 Crore turnover filter. 16. To answer the above question, we need to look at the amendment to the rules that allow for introduction of a range concept for determination of ALP and use of multiple year data for undertaking comparability analysis in transfer pricing cases. The provisions of the Income-tax Act were amended through the Finance (No.2) Act, 2014 to facilitate alignment of Indian transfer regime with international best practices. The manner of computation of ALP is laid down under the Income-tax Rules. The Government has notified the amended Rules for determining ALP vide S.O. No. 2860 (E) dated 19/10/2015. The amended regime will be applicable for computation of ALP of international transactions and specified domestic transactions undertaken on or after 1/04/2014 i.e. on and after PY 2014-15. The amended rules allow for introduction of a range concept for determination of ALP and use of multiple year data for undertaking comparability analysis in transfer pricing cases. The use of range concept being a statistical tool enhances the rel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the comparable uncontrolled transaction or transactions undertaken in the aforesaid period and the price in respect of such uncontrolled transactions shall be determined; and (ii) the weighted average of the prices, computed in accordance with the manner provided in sub-rule (3), of the comparable uncontrolled transactions undertaken in the current year and in the aforesaid period preceding it shall be included in the dataset instead of the price referred to in sub-rule (1): further that in a case referred to in clause (ii) of sub-rule (5) of rule 10B, where the comparable uncontrolled transaction has been identified on the basis of the data relating to the financial year immediately preceding the current year and the enterprise undertaking the said uncontrolled transaction, [not being the enterprise undertaking the international transaction or the specified domestic transaction referred to in sub-rule (1)], has in the financial year immediately preceding the said financial year undertaken the same or similar comparable uncontrolled transaction then, (i) the price in respect of such uncontrolled transaction shall be determined by applying the most appropriate method i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... employed or to be employed, or as the case may be, any other base which has been considered for arriving at the respective prices .. 17. Let us apply the above rules to the comparable company R.S.Software (India) Ltd. As per Rule 10CA(2), the dataset of comparable companies chosen has to be arranged in ascending order. As per the 1st proviso to Rule 10CA(2), R.S.Software (India) Ltd., was chosen as a comparable company based on the data relating to the current year and in the earlier two financial years immediately preceding the current financial year. In all the financial years the said company has undertaken similar comparable uncontrolled transaction. Clause (i) to 1st proviso to Sec.10CA(2) mandates that the same MAM has to be used to arrive at the price of the comparable uncontrolled transaction undertaken by R.S.Software (India) Ltd., in the financial years 2013-14 and 2014-15. As per clause (ii) of 1st proviso to Sec.10CA(2), weighted average of the prices of the 3 financial years have to be taken in accordance with Rule 10CA(3) and the weighted average so taken shall be included data set instead of the price arrived at by using current year data alone. In the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t the question of comparability is not to be seen while applying the 1st and 2nd proviso to Rule 10CA(2) of the Rules. The provisions of Rule 10CA(2) have to be read harmoniously with the other provisions of Rule 10B Determination of arm's length price under section 92C . 10B . (1) For the purposes of sub-section (2) of section 92C, the arm's length price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely : (a) to (d) .. (e) transactional net margin method, by which, (i) the net profit margin realised by the enterprise from an international transaction [or a specified domestic transaction] entered into with an associated enterprise is computed in relation to costs incurred or sales effected or assets employed or to be employed by the enterprise or having regard to any other relevant base; (ii) the net profit margin realised by the enterprise or by an unrelated enterprise from a comparable uncontrolled transaction or a number of such transactions is computed having regard to the same base; ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nts can be made to eliminate the material effects of such differences. (4) The data to be used in analysing the comparability of an uncontrolled transaction with an international transaction [or a specified domestic transaction] shall be the data relating to the financial year [(hereafter in this rule and in rule 10CA referred to as the 'current year')] in which the international transaction [or the specified domestic transaction] has been entered into : Provided that data relating to a period not being more than two years prior to [the current year] may also be considered if such data reveals facts which could have an influence on the determination of transfer prices in relation to the transactions being compared: A reading of Rule 10B(3) shows that comparison of an uncontrolled transaction to an international transaction can be done only if differences, if any, between the transactions that are compared or between the enterprises entering into such transactions are likely to materially affect the price or cost charged or paid in, or the profit arising from, such transactions in the open market or reasonably accurate adjustments can be made to eliminate t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... notice that the coordinate bench of the Tribunal in the case of Barracuda Network India Pvt. Ltd. (supra) has considered exclusion of companies on the ground that related party transactions are more than 15% and has also held that the RPT filter is to be considered on the upper threshold limit of 15% by relying on the decision of the Hon'ble Karnataka High Court in the case of PCIT and Anr. Vs. M.s Yahoo Infotech Pvt. Ltd. The ITAT has made the following observations in this regard: - 22. We are of the view that the facts of the Assessee s case is similar to the case decided by the Hon ble High Court and in the light of the aforesaid decision of the Tribunal which has been upheld by the Hon ble Karnataka High Court, the RPT filter has to be applied adopting the threshold limit of 15%. We hold and direct accordingly. Accordingly, respectfully following the decision of the coordinate bench of the Tribunal we hold that Rheal Software Pvt. Ltd. cannot be excluded on the basis of RPT filter . 20. In view of the above we remit the issue back to the TPO with a direction to verify the RPT transaction of Rheal Software Pvt Ltd and decide the comparability of the company consid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rs. The ld AR submitted that the company is functionally similar to the assessee. The ld AR also submitted that the company passes Rs.1 crore turnover filter for last 2 years and hence the last 2 years margins should be considered for computation purpose. The Ld AR further submitted that the company passes the RPT and export revenue filter and prayed for inclusion of the same. In this regard the ld AR placed reliance on the decision of the coordinate bench of the Tribunal in the case of Huawei Technologies India (P.) Ltd. vs ACIT [2021] 133 taxmann.com 486 (Bangalore - Trib.). 26. We heard the rival submissions and perused the material on record. We notice that in the case of Huawei Technologies(supra) relied on by the assessee I2T2 was included on that ground that the non-availability of Related Party Transaction (RPT) in the annual report cannot be a reason for exclusion. It is also noticed that in the current year, the turnover of the company is less than Rs.1crore and fails the lower turnover filter. We therefore uphold the exclusion of I2T2. 27. Through ground No.7 of concise grounds, the assessee contended the computation of net margin at the entity level by the TPO. Th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ore us, the ld. AR argued that the billing for services rendered by the assessee is done on the basis of time sheets i.e. the time spent by the manpower / employees on services rendered to AEs, non-AEs (pg. 996 of Paper Book). The ld. AR also submitted that the direct expenses attributable to these segments are allocated directly and only expenses that are not identifiable are allocated based on head count since the revenue is based on manpower. The ld. AR further submitted that the segmental financials are prepared based on the audited statement of accounts and is certified by the CA which fact has been admitted by the TPO in his order. The ld DR supported the decision of the lower authorities 30. We have heard the rival contentions and perused the material on record. We notice that the TPO has rejected the segmental financials for the reason that the cost allocated are not proportionate to the revenue reported in each of the segments. It is submitted by the ld.AR that though the assessee has allocated a sum of Rs.3,17,87,219 to the Indian AE segment, there was no billing done as the contract did not go through with the Indian AE. We notice that the coordinate Bench of the Trib ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ses between 10A and non-10A units was considered. In the said case also, the assessee was following allocation of common expenses on the head-count basis. After considering the facts of the said case, the Hon'ble High Court held that the assessee's contention therein that in the service industry head-count method would be more proper is a plausible view though it could possibly be a debatable view. It was held that merely because there can be more than one method of apportioning common expenses between STPI and domestic unit, it cannot be said that the method of head-count followed by the assessee should be discarded that too midway even though it was not questioned at any time in the past. While referring to the observations of the Hon'ble Supreme Court in the case of Hukumchand Mills, the Hon'ble High court observed that where alternative methods of apportioning of expenses are recognized and there is no statutory or fixed formula, the endeavour can only be towards approximation without any great precision or exactness and if such is the endeavour, it can hardly be said that there is an attempt to distort the profits. Thus it can be seen that where two basis of ap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d receivables 32. The TPO considered the outstanding receivable as a separate international transaction and charged notional interest using 6 months LIBOR + 450 basis points which worked out to 5.386% and arrived at TP adjustment of Rs.36,66,083. The assessee raised objections before the DRP contending the levy of notional interest. The DRP confirmed the levy of interest by the TPO. However, the DRP directed the assessee to submit the invoice wise details of realisation and period of delay before the TPO based on which the TPO was directed to compute the interest with reference to the actual period of delay. 33. Before us, the ld.AR submitted that the assessee is a fully funded entity of the AE and the amount outstanding from the AE will be settled on an on-going basis in the normal course of business having regard to the commercial and economic factors. The ld. AR also submitted that the ALP determination for the said receivable is subsumed within the ALP determination of the software development services and therefore the TPO should not have considered the interest on receivables as a separate international transaction. The ld. AR further submitted that the assessee is n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d conclusion distinguished its earlier order in the case of Kusum Healthcare Pvt. Ltd. (supra) and rejected the contention that interest gets subsumed in the working capital adjustment. The Hon`ble Bombay High court in the case of CIT vs. Patni Computer Systems Ltd, (2013) 215 Taxman 108 (Bom) dealt, inter alia, with the following question of law:- (c) Whether on the facts and circumstances of the case and in law, the Tribunal did not err in holding that the loss suffered by the assessee by allowing excess period of credit to the associated enterprises without charging an interest during such credit period would not amount to international transaction whereas section 92B(1) of the Income-tax Act, 1961 refers to any Other transaction having a bearing on the profits, income, losses or assets of such enterprises? While answering the above question, the Hon'ble High Court noticed that an amendment to section 92B has been carried out by the Finance Act, 2012 with retrospective effect from 1.4.2002. Setting aside the view taken by the Tribunal, the Hon'ble High Court restored this issue to the file of the Tribunal for fresh decision in the light of the legislative a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion of the ALP of the international transaction of 'debt arising during the course of business.' This has two ingredients, viz., the amount on which interest should be charged and the arm's length rate at which the interest should be charged. 13.12 In so far as the first aspect is concerned, we find that the TPO has taken normal credit period of 60 days and accordingly made addition on account of transfer pricing adjustment for the period in excess of 60 days. In our considered opinion, transfer pricing adjustment on account of interest for the entire period of delay beyond 60 days cannot be treated as a separate international transaction of trading debt arising during the course of business. It is noticed that the assessee entered into an agreement with its AE for realization of invoices within a period of 150 days. This implies that the interest amount on non-realization of invoices up to 150 days was factored in the price charged for the services rendered. Annexure-1 to the TPO's order gives details of the instances of late realization or non-realization of advances up to the year ending. First three and a half pages of this Annexure indicate number of day ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... such differences'. Applying the prescription of rule 10, it becomes vivid that difference on account of the 'contractual terms of the transactions', which also include the credit period allowed, needs to be adjusted in the profit of comparables. As the TPO has taken the entire delay beyond that normally allowed as a separate international transaction, which position is not correct, we hold that the effect of delay on interest up to 150 days over and above the normal period of realization in an uncontrolled situation, should be considered in the determination of the ALP of the international transaction of 'Provision of IT Enabled data conversion services' and the period of delay above 150 days, namely, 30 days in our above illustration (180 days minus 150 days) should be considered as a separate international transaction in terms of clause (c) of Explanation to section 92B. 13.13 In so far as the question of rate of interest is concerned, we find that this issue is no more res integra in view of the judgment of the Hon'ble jurisdictional High Court in the case of Cotton Naturals (I) (P.) Ltd. (supra), in which it has been held that it is the currency in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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