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The Tax PublishersIT Appeal No 1516 (Ahd) of 2019
2022 TaxPub(DT) 8581 (Ahd-Trib)INCOME TAX ACT, 1961
Section 92C
No interest having been charged by assessee to non-AE outstandings, transaction of outstanding receivables with AE without charging any interest thereon was at arm's length and, therefore, no adjustment on account of notional interest on outstanding receivables from AE was called for.
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Transfer pricing - Determination of ALP - Notional interest on outstanding receivables from AE - No interest charged by assessee on non-AE outstanding
Assessee entered into international transactions with AE. TPO proposed ALP adjustment on account of notional interest on outstanding receivables from AE. Held: It was a fact that on record that the amount invoiced to non-AE was much more than that invoked to AE and with respect to non-AE also assessee had not charged any interest on the outstanding balance, therefore, no adjustment, was called for on account of non-charging of interest on outstanding receivables from AE.
REFERRED :
FAVOUR : In assessee's favour
A.Y. : 2015-16
IN THE ITAT, AHMEDABAD 'D' BENCH
ANNAPURNA GUPTA, A.M. & SUCHITRA RAGHUNATH KAMBLE, J.M.
Toshiba Technical Services International Corpn. v. ACIT
IT Appeal No. 1516 (Ahd.) of 2019
A.Y. 2015-16
12 October, 2022
Appellant by: Yogesh Shah, A.R.
Respondent by: Atul Pandey, Sr. D.R.
Annapurna Gupta, A.M.
Present appeal has been filed by the assessee against order passed by the learned Assistant Commissioner of Income Tax, International Taxation-2, Ahmedabad [hereinafter referred to as 'Ld. ACIT(IT) under section 143(3) read with section 144C(13) of the Income Tax Act, 1961 ('the Act' for short) dated 9-8-2019 pertaining to the assessment year 2015-16.
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