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2022 (8) TMI 1364 - AT - Income TaxALP adjustment in respect of "Interest on Outstanding Receivables" - Prescribed method for determining international transactions - HELD THAT:- We are of the considered view that there is merit in the contentions raised by the ld. AR. As rightly submitted by the ld. AR, the ALP of the international transactions have to be determined by following one of the prescribed methods under the I.T. Rules. Admittedly, the TPO/DRP in the instant case has not followed the same. Accordingly, we deem it proper to remit the issue to the file of AO/TPO for determining the ALP with regard to interest on delayed receivables by following the Rules with a proper benchmarking study. AO/TPO is also directed to rectify the mistakes done in computation of interest raised by the assessee - Appeal by the assessee is allowed for statistical purposes.
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