ALP adjustment for notional interest on account of excess credit period is untenable in law

Brief of the Case ITAT Ahmedabad held In the case of Micro Ink Limited. Vs. ACIT that such interest is includible in operating income and the operating income itself has been accepted as reasonable under method TNMM, there cannot be an occasion to make adjustment for notional interest on delayed realization of debtors. The very conceptual foundation, for separate adjustment for delayed realization of debtors and on the facts of this case, is thus devoid of legally sustainable merits. An adjustment for notional interest on excess credit allowed on sales to AEs will vitiate the picture, inasmuch...