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TP Adjustment - delayed receivables from AE - re-characterizing ...


Interest Adjustment on Delayed Receivables Reversed; No Interest Due for Debt-Free Company with Significant Reserves.

November 25, 2022

Case Laws     Income Tax     AT

TP Adjustment - delayed receivables from AE - re-characterizing the delay in receipt of receivables as unsecured loan, the AO computed interest by applying rate of 4.33% on the basis of 6 months LIBOR with a mark-up of 400 basis point - it is clear that the assessee is more or less a debt free company, whereas, it has substantial reserve and surplus. Thus we hold that no adjustment on account of interest on outstanding receivables can be made in the facts of the present appeal. - AT

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