This is premium content. Please become a Premium member. If you are already a member, login here to access the full content.
Extended credit period to AE attracts TP adjustment
Case Law Details
- Case Name
- M/s Goldstar Jewellery Limited Vs Joint Commissioner of Income Tax (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All ITAT, ITAT Mumbai
Upgrade to Basic or Premium to download.
Already Upgraded? Log in.
CA Manish Soni
Context: The amendment made by Finance Act 2012 (‘FA 2012’) by way of explanation to Sec. 92B w.r.e.f. 1 April 2002 included many transactions in the definition of international transaction for Transfer Pricing (‘TP’) purpose. In this case, the ITAT ruled that extended credit period allowed to the Associated Enterprises (‘AE’) amounted to short term funding without interest and thus attracted TP adjustment on account of notional interest from such short term funding. TPO made adjustment considering interest rate @18.816% but DRP reduced it to ...
