TMI Blog2016 (11) TMI 1647X X X X Extracts X X X X X X X X Extracts X X X X ..... - Tribunal by the impugned order rendered a finding of fact that the respondent assessee has not charged any interest from third parties i.e. Non Associated Enterprises on delayed payments exceeding more than 300 to 400 days from the sale of goods. Consequently, it holds that once such delayed payment in respect of sale of goods made to third parties carries no interest, then adding of notional in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... question of law - Income Tax Appeal No.887 Of 2014 - - - Dated:- 28-11-2016 - M.S.Sanklecha And A.K. Menon, JJ. Mr.Ashok Kotangle a/w. Ms.Padma Divakar and Mr.Arun Nagarjun for the Appellant. Mr.Percy Pardiwala, Senior Advocate a/w. Mr.Atul Jasani for the Respondent. P.C. : 1. This appeal under Section 260A of the Income Tax Act, 1961 (for short &# ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iated Enterprises on sale of goods as compared to the period of credit granted to Non Associated Enterprises. Consequently the notional interest on delayed collection of consideration on sale of goods to Associated Enterprises needs to be added to the declared consideration to arrive at an arms length price. 4. The Tribunal by the impugned order rendered a finding of fact that the respond ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... interest from Associated Enterprises and Non Associated Enterprises for delay in recovery of its sale proceeds. 6. In the present case also the Tribunal has rendered a finding of fact that the interest is not being charged in case of sales made to NonAssociated Enterprises for delayed payment just as in the case of Associated Enterprises. These finding of fact rendered by the Tribunal is ..... X X X X Extracts X X X X X X X X Extracts X X X X
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