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]
Biocon Biologicals Ltd v. ACIT (2025)233 TTJ 930 / 170 taxmann.com 372 (Bang)(Trib)