No TP adjustment for Overdue Receivables which already been considered in working capital adjustment

Bertelsmann Marketing Services India Pvt. Ltd. Vs DCIT (ITAT Delhi) The issue under consideration is whether overdue receivables from AEs is considered as an international transaction? ITAT states that ground is with respect to treating the overdue receivable from associated enterprise as an international transactions however looking to the order of the learned transfer pricing officer after the direction of the learned Dispute Resolution Panel that working capital adjusted margin were considered with respect to all the comparables, therefore, ITAT do not find any reason to further sustain any...