Notional interest for delay in realization of export proceeds from AEs unwarranted: ITAT Mumbai

Strides Pharma Science Limited Vs DCIT (ITAT Mumbai) ITAT Mumbai held that as there is complete uniformity in not charging interest from AEs and Non-AEs for delay in realization of export proceeds, addition of notional interest in respect of transactions with AEs in the course of transfer pricing proceedings unwarranted. Facts- Assessee has contended the action of charging interest on delayed realization of export proceeds from Associated Enterprises. It is mainly contended by the assessee that they are not charging interest on delayed realization either from the Associated Enterprises (AEs) o...