Working capital adjustment subsumes sundry creditors- No further TP adjustment for outstanding receivables

Blue Coat Network (India) Private Limited Vs DCIT (ITAT Bangalore) The issue under consideration is whether TPO is correct in making an upward adjustment to the transfer price of the Appellant’s international transactions on account of imputation of notional interest on outstanding receivables? ITAT states that this issue was considered by this Tribunal in the various cases which held that outstanding sum of invoices is akin to loan advanced by- assessee to foreign AE., hence it is an international transaction as .per explanation to section 92B of the Act. Alternatively, it has been argu...