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Interest calculated solely on Trade Receivables for ALP Determination was unreasonable

RATHI 24 Sep 2024 237 Views 0 comment Print Income Tax | Judiciary

Case Law Details

Case Name : Microchip Technology (India) Private Ltd. Vs DCIT (ITAT Hyderabad)

Appeal Number : ITA No.509/Hyd/2022

Date of Judgement/Order : 11/09/2024

Related Assessment Year : 2018-19

Courts : All ITAT ITAT Hyderabad

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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 payab

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