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2020 (12) TMI 391 - AT - Income TaxTP adjustment - imputing interest on outstanding receivables as on March 31st 2013 relating to sales of services to AE's - HELD THAT:- Outstanding receivable is a separate international transaction and requires to be benchmarked post amendment in Clause (c) of Explanation to Section 92B of the Act by the Finance Act, 2012. However, since in the instant case, the working capital adjustments had been granted by the ld. TPO, on which fact there is absolutely no dispute, the outstanding receivables thereon gets subsumed thereon. Hence, there is no need to make separate adjustment towards outstanding receivables by imputation of interest on the same. This aspect has been considered in assessee's own case for A.Y₹ 2011-12 and 2012-13 [2018 (6) TMI 508 - ITAT HYDERABAD] - we direct the ld. TPO not to make any adjustment by way of imputation of interest on outstanding receivables in the peculiar facts and circumstances of the instant case. Accordingly, the grounds raised by the assessee are allowed in this regard.
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