PCIT v. Avery Dennison (I) (P.) Ltd (2023) 154 taxmann.com 454 (Delhi)(HC) Editorial : SLP of Revenue is dismissed, PCIT v. Avery Dennison (I) (P.) Ltd (2023) 295 Taxman 314 (SC)

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest-Net monthly balance payable-Justified in not charging interest in delayed payments to non-AEs. [S. 260A]

Dismissing the appeal of the Revenue the court held that where the   debtor days given to non-AEs were more than debtor days given to AEs, and assessee had net monthly balance payable to AEs as opposed to monthly balance receivable from AEs assessee was justified in not charging interest on delayed payments by AEs and in not levying any interest on delayed payments made by non-AEs.(AY. 2009-10)