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2023 (4) TMI 1153 - AT - Income TaxTP adjustment - arm’s length price determination of outstanding receivables - TPO characterized overdue receivables from the AEs as a deemed loan stating that it constitutes a separate international transaction - HELD THAT:- We are under the jurisdiction of Hon’ble Delhi High Court. The ITAT in several recent decisions has found that the decision of Hon’ble Delhi High Court in the case of Pr. CIT vs Kusum Health Care (P.) Ltd. [2017 (4) TMI 1254 - DELHI HIGH COURT] continuous to be a binding precedent. Thus we set-aside the orders of the authorities below and delete the transfer pricing adjustment in respect of arm’s length price determination of outstanding receivables.
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