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ITAT adjudicated a transfer pricing dispute involving comparability analysis and interest computation on outstanding receivables. The tribunal rejected certain comparator companies as functionally dissimilar. Regarding notional interest, ITAT held that TPO must conduct a comprehensive transfer pricing study considering credit periods and applicable LIBOR rates. The tribunal remanded the matter to the AO/TPO, directing that if working capital adjustment encompasses outstanding receivables, no separate characterization is required. For receivables outside working capital, the interest rate should be LIBOR plus 300 basis points, consistent with judicial precedent, with a 90-day credit consideration.
ITAT adjudicated a transfer pricing dispute involving comparability analysis and interest computation on outstanding receivables. The tribunal rejected certain comparator companies as functionally dissimilar. Regarding notional interest, ITAT held that TPO must conduct a comprehensive transfer pricing study considering credit periods and applicable LIBOR rates. The tribunal remanded the matter to the AO/TPO, directing that if working capital adjustment encompasses outstanding receivables, no separate characterization is required. For receivables outside working capital, the interest rate should be LIBOR plus 300 basis points, consistent with judicial precedent, with a 90-day credit consideration.
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