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4. Having considered the rival submissions and careful perusal of record, we note that the assessee's operative margin from the ACIT Vs. M/s Vijay Solvex Limited trading of bakery shortening is at 1.63% whereas the TPO while determining the arm's length price by applying the TNMM as most appropriate method and OP/Total Cost (TC) as PLI has arrived at Mean margin of 4.07%. Therefore, the price of international transaction undertaken by the assessee is within the tolerance range of (+)(-) 5% of the arm's length price determined by the TPO. Accordingly, as per the second proviso to section 92C(2) the price of international transaction in respect of purchase of bakery shortening will be determined at arm's length price and consequently no adjustment is called for on this account. Hence in view of the fact that the price of international transaction is within the tolerance range as provided under the second proviso to section 92C(2), we do not go into the issue of most appropriate method applied by the assessee as well as by the TPO. Accordingly, we do not find any reason to interfere with the order of ld. CIT (A) qua this issue. Hence, subject to the verification of the import expenses, we do not find any reason to interfere with the order of the ld. CIT(A) qua this issue. Since we found that even as per the TNMM method applied by the TPO, the assessee's international transactions would be at arm's length. 5.5 The second adjustment on account of notional interest on the receivables from AE. We have heard the ld DR as well as the ld. AR of the assessee and considered the relevant material on record. We find that the assessee has not charged any interest from AE as well as from non AE in respect of sales realization and allowed credit period to both the parties. The TPO noted that the credit period allowed by the assessee to the AE is abnormal in comparison to the non AE from the transactions and therefore, there is a substantial delay in realization of trade debts from ACIT Vs. M/s Vijay Solvex Limited AE. The TPO, accordingly, took the arm's length interest @ 17.26% and made adjustments by computing the credit period after allowing a normal period of 60 days. At the outset, we note that the allowing credit to the AE on realization of trade debts is not an independent transaction as per the existing provisions of Section 92B of the Act and at the most the same will be part of international transaction of sales made to the AE. The Assessing Officer found the international transaction of sales to the AE at arm's length, therefore, there is no dispute that the main transaction was found to be at arm's length and only the notional interest on the realization of trade debts was taken as a separate transaction by the TPO for making a separate adjustment for delay in realization. Thus, once the TPO has considered the TNMM as most appropriate method then the delay in realization of debt and consequential interest income which was not received or recovered by the assessee from AE could have been factored in computing the operating margin of the assessee in respect of the international transaction of sale made to the AE instead of considering the notional interest for delay in realization of debts as a separate international transaction. We further note that the arm's length interest in respect of realization from AE based at UK shall be LIBOR instead of PLR/Profit margin taken by the TPO. Since the realization is from the AE and in the foreign currency, therefore, the LIBOR would be the appropriate comparable arm's length rate. Hence, by considering all these ACIT Vs. M/s Vijay Solvex Limited facts and circumstances when the assessee's operating margin from the international transaction of the sale is more than 17% which was found to be at arm's length then even if the interest on delayed realization of trade debts from AE is given into effect it will not bring the international transaction from the category of arm's length to short price charged from the AE as the assessee would get the benefit of second proviso of Section 92CA of the Act and in any case the LIBOR rates is not exceeding 2 to 3% and further only friction of the total sale is considered as delayed realization of trade debts. Accordingly, in the facts and circumstances, we do not find any justification in making separate addition on this account. Hence, we do not find any merit in the grounds raised by the revenue. 5.6 The third adjustment made on account of interest on loan advanced to the UK based AE. We have heard the ld. DR as well as the ld AR of the assessee and considered the relevant material on record. At the outset, we note that this issue was considered by this Tribunal in assessee's own case for the A.Y. 2007-08 vide order dated 03/4/2018 in para 6 as under:

"6. We have heard the Id. D/R as well as the Id. A/R and considered the relevant material on record. There is no dispute that the assessee has advanced a loan in foreign currency to its AE and charged interest @ 10%. We find that the issue of charging interest from AE in respect of the money advanced in foreign currency, the arm's length interest is to be considered by taking the LIBOR instead of PLR. The Id. CIT (A) has considered this issue in para 4.1 as under:-

The application of LIBOR rate of interest was upheld by Hon'ble Delhi Tribunal in the case of Perot Systems TSI (India) Limited Vs. DCIT (37 SOT

358). The LIBOR rate during the relevant period was 4.31% to 5.77 % in the FY 2006-07. The TPO in this case had applied the monthly LIBOR (London International Bank Official Rate) downloaded from the British Bankers Association website. During the financial year 2001-02 LIBOR for US dollar loan was 2.39%. On that LIBOR, the Assessing Officer added average basis point charged by other companies and for this purpose he took rate for 5 companies. The arithmetic mean came to 1.64%. Accordingly, Assessing Officer computed the arm's length rate to be LIBOR + 1.64% using CUP method. However the application of the LIBOR rates in the case of loans and advances to associate enterprise (AE) located outside the geographical boundaries of India was upheld by judicial authorities. The LIBOR rate during the relevant period ranged from 5.20% to 5.44% and after adding thereto 1.64% average basis point as upheld by Income-Tax Appellate Tribunal, Bench-Delhi, the effective arm's length rate of interest worked out to 6.84% to 7.08% as against that the appellant company had charged the interest @ 10%. In the present case, the rate of interest on the borrowing from SBBJ was 8.75% at the relevant point of time i.e. at the time of giving of loan, as against that the appellant had charged the rate of interest @ 10% on the amount lent the associate enterprise (AE) much higher than the comparable uncontrolled price (CUP) rate. The rate of interest charged from the associate enterprise (AE) was mentioned erroneously as 9%, whereas it was 10%, which was verifiable from the credit note sent by the M/S Data Houseware P Ltd. U.K. associate enterprise (AE) dated 31.03.2007. Further the associate enterprise (AE) had utilized the loan in its stock and debtors, which was apparent from the balance sheet of the associate enterprise (AE). The assessee had not incurred any brokerage or processing fees in advancing loan to the associate enterprise (AE).The appellant company had not given any loan or advances to Data Foods (P) Limited., Sri Lanka during the financial year 2006-07. Accordingly the adjustment made on account of loan given to ACIT Vs. M/s Vijay Solvex Limited M/S Data Houseware (P) Ltd., U.K. was not justified. Further the appellant was a secured creditor as it had sold goods to the concerned AE also. The position of the appellant company was that of a unpaid seller since the AE owed to it an amount comprising of loan as well as amount for goods purchased. Therefore the TPO had erroneously held that the position of the appellant was that of a unsecured creditor/loanee. I accordingly direct the AO to delete the addition of Rs 2,55,929/-made on account of adjustments made by the TPO. This ground of appeal is allowed." Thus it is clear that the Id. CIT (A) has followed the decision of this Tribunal on this issue and accordingly we do not find any error or illegality in the order of Id. CIT (A) qua this issue.