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2016 (3) TMI 1420 - ITAT MUMBAITP Adjustment - deemed interest on delayed sale proceeds - scope of definition of international transaction under Section 92B - interest for delay of 16, 7 and 7 days in respect of these delays (180 days was taken as the benchmark of reasonable period for realization of debts) by computing interest @ 18.816% - impact of amendment in section 92B, by the virtue of Finance Act 2012 - HELD THAT:- As decided in RUSABH DIAMONDS [2016 (4) TMI 400 - ITAT MUMBAI] no ALP adjustments can be made, on the facts of this case, in respect of delay in realization of sale proceeds. The amendment in Section 92B, at least to the extent it dealt with the question of issuance of corporate guarantees, is effective from 1st April 2012. The assessment year before us being an assessment year prior to that date, the amended provisions of Section 92 B have no application in the matter. - Decided in favour of assessee
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