Dismissing the appeal of the revenue the Tribunal held that during the year under consideration, the assessee had neither charged interest on its receivables nor had paid any interest on its payables to its associated enterprises. No notional interest could be charged on amounts due from associated enterprises. The adjustment made by the Transfer Pricing Officer was to be deleted. (AY. 2014-15).
JCIT v. Reliance Life Sciences Pvt. Ltd. (2021) 91 ITR 468 (Mum.) (Trib.)
S. 92C : Transfer pricing-Arm’s length price-Remittance of funds by assessee to its Associated Enterprises by way of share application money and loan-Assessee neither charging interest on its receivables nor paying any interest on its payables to its Associated Enterprises-Notional interest could not be charged on amounts due from Associated Enterprises-No adjustment warranted.