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TMI Blog2024 (9) TMI 27X X X X Extracts X X X X X X X X Extracts X X X X ..... urt and stated that they have no quarrel to the proposition laid down by the aforesaid judgement that once working capital adjustment is granted to the assessee, there is no need for further imputation of interest on outstanding receivables at the end of the year as the same gets subsumed in the working capital adjustment. After agreeing with this proposition, the Tribunal has directed the TPO to once again look into the bills submitted by the appellant and directed TPO to ascertain whether interest is to be imputed on bills that have been realised after credit period of 70 days. In our view, the direction given to the TPO to examine the bills is correct, however, the direction for imputing interest on the bills was not necessary and the TP ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rinciples laid down by the Courts that once working capital adjustment is granted to the assessee, there is no need for further imputation of notional interest on outstanding receivables at the end of the year as the same gets subsumed in the working capital adjustment? D. Whether the Ld. Tribunal erred in not appreciating that the Appellant- Assessee has maintained complete uniformity and has not charged any interest from both relates and unrelated party and hence there is no differential treatment between alleged AE and other parties? E. Whether the Ld. Tribunal grossly erred in simply accepting the TPO / AO's order without providing any cogent reasoning for upholding it and without conducting any enquiry despite evidence being specif ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er its dues from its AEs. Hence, the Id. TPO is directed to look into the following:- (a) In respect of bills raised on or after 01.04.2010 to its AEs, what was the date of realization and whether the same has been realized within the credit period allowed of 70 days. If not, interest is to be imputed on those bills also. (b) In respect of outstanding bills as on 01.04.2010 (i.e., opening balance) from these AEs, what was the date of realization thereof and if the bills are realized beyond the granted credit period of 70 days, interest is to be imputed on those bills also. 5. In our view, the direction given to the TPO to examine the bills is correct, however, the direction for imputing interest on the bills was not necessary and the TPO is ..... X X X X Extracts X X X X X X X X Extracts X X X X
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