TP Adjustment - interest on outstanding receivables - The ...

Interest Imputation on Delayed Receivables: Indirect Funding by AEs Requires Arm's Length Price Adjustment.

December 14, 2020

Case Laws Income Tax AT

TP Adjustment - interest on outstanding receivables - The realization of invoices were made with abnormal delay. This, in our considered opinion, tantamount to indirect funding made by the assessee to its AEs by allowing the AE to utilize funds of the assessee as per its whims and fancies. Merely because the assessee is a debt free company, it cannot allow its funds to be utilized by its AE for an indefinite period of time beyond the agreed credit period. - the outstanding receivables from AE constitute a separate international transaction and on which interest is to be imputed thereon and consequently ALP adjustment to be made. - AT

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TP Adjustment - interest on outstanding receivables - The ...

Interest Imputation on Delayed Receivables: Indirect Funding by AEs Requires Arm's Length Price Adjustment.

December 14, 2020

Case Laws Income Tax AT

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