No Interest Adjustment for AE if No Interest Charged from Unrelated Third Party

PCIT Vs Global Logic India Ltd. (Delhi high Court) In the case of PCIT vs Global Logic India Ltd., the Delhi High Court reviewed whether deferred payments to foreign-associated enterprises constitute international transactions under Section 92B of the Income Tax Act, 1961. The Court referred to the precedent set in PCIT vs Kusum Health Care Pvt. Ltd., where it was held that not every receivable qualifies as an international transaction unless it reflects a pattern benefiting the associated enterprise. The Tax Department argued that Global Logic India’s practice of deferred payments from 2010...