Case Law Details
Transfer Pricing – Notional Interest on Excess Credit Period/ Delayed Payment as International Transaction
The treatment of extended credit period to Associated Enterprises(AEs) as an international transaction and making adjustment of notional interest on the same has always been bone of contention between the assessee and department.
In a recent case of Tally Solutions Pvt. Ltd. Vs. ACIT (I.T.(T.P) A. No.1364/Bang/2011) as reported in [TS-620-ITAT-2016(Bang.)], interest free credit period allowed to AE by assessee was held by ITAT to be an international transaction but not a separate transaction from sale of services. Brief facts and analysis of the case are as under: Please become a Premium member. If you are already a Premium member, login here to access the full content.
