207, Gupta Archade LSC Delhi. Plot No. 05, Mayur Vihar, Phase1 Extension, Delhi 110 001 PAN AABCI2526F (Appellant) (Respondent) Assessee by: Shri Neeraj Jain, Advocate Mr. Abhishek Aggarwal, CA, Ms. Shubhangi Jain, CA Department by: Shri Mahesh Shah, CIT(DR) Date of Hearing: 16.06.2022 Date of 23.11.2022 pronouncement ORDER PER ASTHA CHANDRA, JM: The appeal of the assessee arises out of the order dated 30.12.2021 of the Ld. Addl./Joint/Dy./ACIT/ITO, National Faceless Assessment Centre, Delhi ("AO") under section 143(3) r.w.s. 144C of the Income Tax Act, 1961 (the "Act") pertaining to the assessment year ("AY") 201718. 2. The issue raised in the assessee's appeal is against the addition of Rs. 7,44,36,493/ on account of transfer pricing adjustment with respect to international transaction of provision of software development services and addition of Rs. 7,12,59,891/ with respect to interest on delay in receipt of receivables from Associated Enterprises ("AEs"). ITA No. 370/Del/22 3. The assessee is a wholly owned subsidiary of Global Logic Inc. and is engaged in the provision of software development services to its customers including Global Logic Group entities. Additionally, the assessee also provides IT enables Services ("ITeS") to certain third party entities. For the services rendered to its AEs, it is remunerated on a cost plus markup basis. 4. During AY 201718, the assessee entered into the following international transactions with its AEs: A. International Transactions Associated Nature of transaction Total value of Enterprise transaction (in Rs.) Global Logic Provision of software 3,38,12,46,071 Inc. development services Global Logic Provision of software 24,36,671 Israel Ltd. development services Global Logic Reimbursement of expenses 7,57,357 Inc. paid to AE Global Logic Reimbursement of expenses 11,99,27,155 Inc. received from AE B. Deemed International Transactions Associated Deemed International Transfer Price Enterprise Transaction (in Rs.) Oracle India Provision of software 17,12,280 Pvt. Ltd. development services 5. In its transfer pricing report for the financial year ended 31.03.2017, the assessee has reported that in respect of international transactions pertaining to provision of software development services to its AEs, the assessee has determined the Transactional Net Margin Method ("TNMM") as the most appropriate method under section 92C of the Income Tax Act, 1961 ("Act"). The assessee is operating margin for the financial year ended 2 ITA No. 370/Del/22 March 31, 2017 was compared with margins of comparable companies and accordingly, the amount receivable as computed by the assessee having regard to the ALP is the amount receivable as per his books of account. Further international transactions pertaining to provision of software development services (deemed international transaction), reimbursement of expenses to AE and accounts receivable/accounts payable/advances from all AEs has been closely linked to the main international transaction pertaining to 'provision of software development services'. It is also reported that the assessee has incurred certain expenses on behalf of its AE and the same has been cross charged by the assessee on cost to cost basis. Accordingly, the subject transaction pertaining to reimbursement of expenses from the AE has been benchmarked using "other method" as prescribed under Rule 10AB of the Income Tax Rules, 1962 ("IT Rules"). 6. As can be seen from the table in para 4 above, the assesee has reported the international tran