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2019 (8) TMI 512 - HC - Income TaxTP Adjustment - Arm’s Length Price (ALP) determination u/s 92CA(3) - absence of interest, claimed from an Associated Enterprises, (A.E.) notional amounts could be attributed in the income - HELD THAT:- In B.C. Management Services (P) Ltd [2017 (12) TMI 255 - DELHI HIGH COURT] the Court had held following Principal CIT vs. Bechtel India (P) Ltd. [2016 (9) TMI 196 - DELHI HIGH COURT] that such notional income on account of delayed payment by the A.E. cannot be treated as part of the income and made the subject matter of the adjustments. This Court is of the opinion that since no amounts were advanced in the instant case, rather the adjustments made on account of TPO that ought to have been recovered from the notional interest, on a subjective assessment of the manner in which the businesses run, no question of law arises for consideration.
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