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| The Tax Publishers2020 TaxPub(DT) 3443 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
As assessee had been granted working capital adjustment while computing ALP of international transaction of sale of services, accordingly no separate benchmarking was to be done of outstanding receivable as outstanding receivable was part of working capital of assessee.
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Transfer pricing - Determination of ALP - Notional interest in relation to delay in receipt of receivable from - Working capital adjustment already granted to assessee
Assessee entered into transactions with its AE abroad. TPO suggested ALP adjustment on account of notional interest in relation to delay in receipt of receivable from AE. Held: As assessee had been granted working capital adjustment while computing ALP of international transaction of sale of services, accordingly no separate benchmarking was to be done of outstanding receivable as outstanding receivable was part of working capital of assessee.
Applied:Pr. CIT v. Kusum Healthcare Private Limited ITA No. 765/2016 : 2017 TaxPub(DT) 4367 (Del-HC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2011-12
INCOME TAX ACT, 1961
Section 32(1)
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