https://www.taxtmi.com/article/detailed?id=6963 The ITAT held that allowing an extended interest free credit period to an associated enterprise is an international transaction because it is capable of generating income, and directed AO/TPO to aggregate the credit period effect with the sale of services when determining the arm's length price rather than treating the credit as a separate loan transaction; the author notes conflicting authorities holding that non charging of interest does not always amount to an international transaction and that factual business norms may preclude notional interest adjustments. en-us Mon, 05 Sep 2016 11:59:13 +0530 Mon, 05 Sep 2016 11:59:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=6963 The ITAT held that allowing an extended interest free credit period to an associated enterprise is an international transaction because it is capable of generating income, and directed AO/TPO to aggregate the credit period effect with the sale of services when determining the arm's length price rather than treating the credit as a separate loan transaction; the author notes conflicting authorities holding that non charging of interest does not always amount to an international transaction and that factual business norms may preclude notional interest adjustments. Articles Income Tax Mon, 05 Sep 2016 11:59:13 +0530 https://www.taxtmi.com/article/detailed?id=6963