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Income Tax - Highlights / Catch Notes

Home Highlights July 2019 Year 2019 This

TP Adjustment - ALP of interest on receivables - no credit ...


TPO Must Use Annual Average Collection Period for Transfer Pricing Adjustments on Receivables Exceeding 90 Days.

July 24, 2019

Case Laws     Income Tax     AT

TP Adjustment - ALP of interest on receivables - no credit period was agreed between the parties - TPO should not calculate the collection period selectively which are beyond 90 days, he has to calculate the average of collection for the year under consideration of all the transactions - the adjustment only to the extent it crossed 90 days

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