Tribunal held that when the assessee was adopting the uniform policy of not charging interest for delay in realisation of export receivables from associated enterprises and non- associated enterprises and the transactions with regard to sale of cut and polished diamonds had been accepted by the Transfer Pricing Officer to be at the arm’s length price, no addition for notional interest was warranted. Followed ACIT v. v. Gitanjali exports corporation ltd. [2017 81 taxmann.com 452 (Mum) ( Trib) ( AY.2009-10)
S. Vinodkumar Diamonds P. Ltd. v Dy. CIT (2020) 81 ITR 46 (SN) (Mum) (Trib)
S.92C: Transfer pricing — Arm’s Length Price — Delay in realisation of trade debts — Uniform policy -Associated enterprises and non- enterprises — Addition of notional interest is held to be not justified . [ S.92B ]