Tribunal held that for recovery of outstanding expenses ,interest ,period of 60 days reasonable within which expenses ought to have been recovered .SBI-PLR rates alone should be calculated without any 3 per cent spread.8.15 Per Cent should be adopted while calculating Arm’s Length Price interest.Opportunity cost to assessee’s funds to be calculated in relation to interest earning capacity in domestic market.( AY.2012-13)
Allianz Cornhill Information Services P. Ltd. v. DCIT (2018) 65 ITR 33 (SN) (Cochin) (Trib)
S.92C:Transfer Pricing — Arm’s Length Price —Outstanding expenses — Interest — Period of 60 days reasonable within which expenses ought to have been recovered—SBI-PLR rates alone should be calculated without any 3 per cent spread.8.15 Per Cent should be adopted while calculating Arm’s Length Price interest — Opportunity cost to assessee’s funds to be calculated in relation to interest earning capacity in domestic market. [ S.92B ]