https://www.taxtmi.com/caselaws?id=258298 The ITAT Delhi upheld the assessee's method of aggregating international transactions and receivables for transfer pricing purposes, rejecting the addition of notional interest on receivables outstanding beyond 180 days. The tribunal found that the assessee's working capital adjustment adequately accounted for outstanding receivables by adjusting profitability margins of comparable companies. Since the assessee's pricing exceeded the working capital-adjusted margins of comparables, no further interest imputation was warranted. The approach aligned with established transfer pricing principles and relevant HC precedent. The AO/DRP's enhancement of income on account of notional interest was therefore set aside, ruling in favor of the assessee. en-us Tue, 31 Mar 2015 00:00:00 +0530 Wed, 30 Jul 2025 16:24:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=258298 The ITAT Delhi upheld the assessee's method of aggregating international transactions and receivables for transfer pricing purposes, rejecting the addition of notional interest on receivables outstanding beyond 180 days. The tribunal found that the assessee's working capital adjustment adequately accounted for outstanding receivables by adjusting profitability margins of comparable companies. Since the assessee's pricing exceeded the working capital-adjusted margins of comparables, no further interest imputation was warranted. The approach aligned with established transfer pricing principles and relevant HC precedent. The AO/DRP's enhancement of income on account of notional interest was therefore set aside, ruling in favor of the assessee. Case-Laws Income Tax Tue, 31 Mar 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=258298