Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights March 2024 Year 2024 This

TP Adjustment - Interest on delayed receivables - The ITAT found ...


Interest on Delayed Receivables: Separate International Transaction, Requires Thorough Investigation by TPO.

March 16, 2024

Case Laws     Income Tax     AT

TP Adjustment - Interest on delayed receivables - The ITAT found that the conditions laid down by previous rulings, specifically in the case of PCIT vs. Kusum Healthcare, were met, justifying the inclusion of interest on delayed receivables as a separate international transaction. The Tribunal emphasized the need for proper inquiry by the Transfer Pricing Officer (TPO) over time to identify patterns indicating benefits to AEs, and rejected the appellant's argument that the receivables' impact was already considered in the working capital adjustment.

View Source

 


 

You may also like:

  1. The ITAT Hyderabad addressed a Transfer Pricing (TP) Adjustment issue regarding interest on outstanding receivables, determining if it constitutes an international...

  2. TP Adjustment - notional interest on outstanding receivables due from Associated Enterprises (AES) - assessee not charging any interest from its AEs - Treatment of...

  3. ITAT upheld characterization of outstanding dues beyond agreed credit period as separate international transaction of providing finance, requiring separate benchmarking....

  4. TPA - ALP - interest on delayed realization of receivables is a separate international transaction and, therefore, requires separate benchmarking. It has nothing to do...

  5. TPA - Addition in respect of ALP in respect of receivables due from AEs - Early or late realization of sale proceeds is only incidental to transaction of sale, but not a...

  6. TP Adjustment - interest on delayed receivables - Assessee pleaded that the deferred receivables do not constitute a separate international transaction requiring...

  7. Outstanding receivables from AEs exceeding agreed credit period constitutes separate international transaction of providing capital financing/lending receivables, not...

  8. TPA - receivables forming a part of international transaction - TPO is not justified in concluding that the figure of receivables beyond 180 days constitutes an...

  9. TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held...

  10. The ITAT held that outstanding receivables from Associated Enterprises constitute an international transaction requiring separate benchmarking under section 92B...

  11. TP Adjustment - Eligible International Transaction - safe harbor rules - The court examined the eligibility of international transactions under Rule 10TC of the Income...

  12. TP adjustment regarding interest on outstanding receivables - “interest on receivables” is an international transaction during the FY and the decisions rendered prior to...

  13. Transfer pricing adjustment - Early or late realization of sale proceeds is only incidental to transaction of sale, but not a separate transaction in nature. - the...

  14. Transfer pricing adjustment made because of interest charged on delayed receivables - As before the TPO the assessee had furnished certain evidences including the bank...

  15. TP Adjustment made on account of interest chargeable on outstanding receivables - applying LIBOR rates - adoption of SBI prime lending rate @14.45% is definitely...

 

Quick Updates:Latest Updates