ALP adjustment for excess credit period to AEs without charging any interest

CA Reetika Agarwal ITAT Bengaluru held in the case of Nuance Transcription Services India (P.) Ltd. v Dy. CIT that Outstanding Receivables from AE is an international transaction as per Explanation to Section 92B inserted by the Finance Act 2012 and non-charging of interest for a period exceeding 6 months requires ALP adjustment. Issue: Whether transaction of allowing excess period of credit to Associated Enterprises without charging any interest during such credit period would amount to International Transaction within the meaning of section 92B of the Act? Hon’ble ITAT held: 1. That this ...