ACIT v. Intas Pharmaceuticals Ltd. (2025) 236 TTJ 550/ 174 taxmann.com 867 (Ahd)(Trib)

S. 92C: Transfer pricing]-Arm’s length price-Avoidance of tax-International transaction-Not charging interest on late realisations of receivables-Addition made towards notional interest on delayed receivables from AEs is deleted.

Held that the Assessee benchmarked its international transactions of export of finished goods to AEs under the TNMM, and made a working capital adjustment while computing the PLI; receivables due from the AEs are merely an extension of the main international transaction of sale of goods and do not constitute a separate international transaction warranting an independent adjustment. (AY. 2015-16)

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