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2023 (6) TMI 258 - AT - Income TaxTP adjustment - global/regional management overhead allocation fee - HELD THAT:- Considering the similarity of the issue and view taken in the earlier assessment years [2021 (10) TMI 1382 - ITAT HYDERABAD] and [2022 (12) TMI 457 - ITAT HYDERABAD] by a Co-ordinate Bench, we are of the considered opinion that the interest of justice would be met by restoring this issue to the file of the learned Assessing Officer in view of the need for the assessee to file the additional documentary evidence in support of their claim. Interest on trade receivable - Ends of justice would be met by accepting the interest rate on similar foreign currency receivables/advances as LIBOR+200 points. We direct the AO / learned TPO to adopt the same. Grounds are partly allowed accordingly.
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