Interest calculated solely on Trade Receivables for ALP Determination was unreasonable

Microchip Technology (India) Private Ltd. Vs DCIT (ITAT Hyderabad) Conclusion: When assessee had both trade receivables and trade payables, it would be unreasonable to calculate interest only on trade receivables for the purpose of determining the ALP of the transaction. AO/ TPO was directed to consider both trade payables and trade receivables for the purpose of notional interest to be charged for determining the ALP value of the transaction. Held: Assessee-company challenged the legality of the assessment order on the ground that AO passed the assessment order on a non-existent entity, conse...