Held that outstanding dues beyond an agreed credit period are separate international transaction, which requires to be bench marked separately and cannot be clubbed together with other transactions; since the argument of the assessee that the working capital adjustment subsumed accrued interest on trade receivables, and no separate adjustment should be made was not advanced before the TPO or the DRP, this issue is restored back to the TPO. (AY. 2020-21)
Biocon Biologicals Ltd v. ACIT (2025)233 TTJ 930 / 170 taxmann.com 372 (Bang)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on outstanding receivables from AES-Outstanding dues beyond an agreed credit period are separate international transaction, which requires to be benchmarked separately and cannot be clubbed together with other transactions-Working capital adjustment subsumed accrued interest on trade receivables, and no separate adjustment should be made was not advanced before the TPO or the DRP-, Issue is restored back to the TPO.[R. 10A]
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