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| The Tax Publishers2021 TaxPub(DT) 0196 (Chen-Trib) INCOME TAX ACT, 1961
Section 92C
Once TNMM method was considered as the most appropriate method, net margin worked out thereunder could take care of all such notional interest cost, wherever it could be imputed and there could be no arm's length price adjustment for any overdue receivables.
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Transfer pricing - Determination of ALP - Interest on outstanding receivable from AE - Assessee having adopted TNMM method
TPO suggested ALP adjustment on account of notional interest on outstanding receivable from AE. Assessee pleaded to have adopted TNMM as the MAM. Held: Once TNMM method was considered as the most appropriate method, net margin worked out thereunder could take care of all such notional interest cost, wherever it could be imputed and there could be no arm's length price adjustment for any overdue receivables.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2015-16
IN THE ITAT, CHENNAI BENCH
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