In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes
price adjustment be made to the income of the assessee in relation to the said transaction. 41. Taking up first the issue of characterization of delayed payment of receivables beyond 60 days as international transactions u/s 92B of the Act, we find that the AO/TPO and the DRP both have relied upon the insertion of Explanation below section 92B