Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2023 (6) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (6) TMI 969 - AT - Income TaxTP Adjustment - addition pertaining to interest on outstanding receivables - DRP have erred in rejecting the economic analysis undertaken by the Appellant by conducting a fresh economic analysis for the impugned transaction - HELD THAT:- We note that the ITAT in assessee’s own case for immediately preceding assessment year i.e. AY 2015-16 [2023 (2) TMI 1105 - ITAT DELHI] on the impugned issued as held since the assessee has provided similar services to unrelated parties and claims that no interest was charged with respect to outstanding receivables from unrelated parties, in all fairness, this contention cannot be brushed aside lightly, though needs due verification by lower authorities. We, therefore, restore this issue to the file of the TPO/AO. Assessee is directed to furnish necessary documentary evidences to demonstrate that on outstanding receivables from unrelated parties, no interest was charged on similar transactions as that with AEs and the Assessing Officer/TPO is directed to examine the same and decide the issue afresh as per provisions of law.
|