2013 (1) TMI 804 - BOMBAY HIGH COURT

Additions on account of adjustment made to arms length price in respect of international transactions - Held that:- similar question raised by the Revenue in the Assessee's own case being Income Tax Appeal No. 6869 of 2010 - thus adjustment made to arms length price cannot be entertained

Deletion of addition being interest receivable on outstanding amount - Held that:- interest income is associated only with the lending or borrowing of money and not in case of sale - the specific finding of the ITAT is that there is complete uniformity in the act of the assessee in not charging interest from both the Associated Enterprises and Non Associated Enterprises debtors and the delay in realisation of the export proceeds in both the cases is same - hence there is no reason to entertain the matter - Appeal is accordingly dismissed with no order