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)
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.
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