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2018 (6) TMI 508 - AT - Income TaxTP adjustment - International transaction - notional interest on outstanding receivables - Held that:- Assessee is a zero debt company, fully funded by AE, no interest liability and assessee also did not charge any outstanding amount even from third parties, therefore question of charging interest on the outstanding amount does not arise. Following the decision in case of Pegasystems Worldwide India Pvt Ltd., Vs ACIT [2015 (10) TMI 2495 - ITAT HYDERABAD] it is held that there is no need or bringing to tax the notional interest on the outstanding receivables - thus no TP adjustment can be made - since the very addition is not confirmed, the issue on rate of interest as raised by Revenue in its appeal becomes academic and infructuous - appeal of revenue is dismissed.
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