Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Clause (e) of section 43B, as amended to include interest payable to co-operative banks effective 01-04-2018, does not apply to assessment year 2017-18 unless the assessee qualified as a scheduled bank; a notified scheduled bank was already covered pre-amendment. Because the assessee did not pay interest due to Punjab and Maharashtra Co-operative Bank on or before the due date for filing under section 139(1), the interest is disallowable under section 43B. Capitalization of such interest into work-in-progress does not prevent the disallowance; decision favours revenue.
Clause (e) of section 43B, as amended to include interest payable to co-operative banks effective 01-04-2018, does not apply to assessment year 2017-18 unless the assessee qualified as a scheduled bank; a notified scheduled bank was already covered pre-amendment. Because the assessee did not pay interest due to Punjab and Maharashtra Co-operative Bank on or before the due date for filing under section 139(1), the interest is disallowable under section 43B. Capitalization of such interest into work-in-progress does not prevent the disallowance; decision favours revenue.
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