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2020 (12) TMI 778 - AT - Income TaxTP Adjustment - adjustment made to international transaction of ‘Engineering Design’ and related ‘Services’ - Comparable selection - HELD THAT:- Companies functionally dissimilar with that of assessee need to be deselected from final list. Transfer pricing adjustment for interest on receivables - HELD THAT:- In the instant case, the Learned DRP has noted the decisions of the Tribunal and High Court in the earlier years. In assessment year 2010-11 the Tribunal in the case of Kusum Healthcare Private Limited [2015 (4) TMI 180 - ITAT DELHI] and held that impact of credit period was duly factored in working capital adjustment allowed while determining the arm’s-length price and, therefore, no separate adjustment for interest on receivables was warranted in the hands of the tested party.
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