Tribunal held that , non-charging or under-charging of interest on excess period of credit allowed to AE for realization of invoices amounts to an international transaction and ALP of such an international transaction is required to be determined
Pitney Bowes Software India (P) Ltd. v. Addl. CIT(2018) 63 ITR 37 (SN)(Delhi ) (Trib))
S. 92C:Transfer pricing – Non-charging or under-charging of interest on excess period of credit allowed to AE for realization of invoices amounts to an international transaction and ALP of such an international transaction is required to be determined .