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The Tax PublishersITA No. 2228/Hyd/2017
2020 TaxPub(DT) 5289 (Hyd-Trib)INCOME TAX ACT, 1961
Section 92B
With introduction of Explanation to section 92B, interest on receivables constitute international transaction and separate adjustment was required to be made on account of interest on delayed payments.
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Transfer pricing - International transaction - Interest on delayed receivables from AE -
TPO suggested ALP adjustment on account of interest on delayed receivables from AE. Assessee's case was that interest on receivables did not constitute international transaction. Held: With introduction of Explanation to section 92B, interest on receivables constitute international transaction and separate adjustment was required to be made on account of interest on delayed payments.
Followed:Infor (India) (P) Ltd. ITA No. 1689/Hyd/019, Order, dt. 19-10-2020
REFERRED :
FAVOUR : Against the assessee.
A.Y. :
IN THE ITAT, HYDERABAD BENCH
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