https://www.taxtmi.com/caselaws?id=396951 Delayed realisation of trade receivables from an associated enterprise beyond the agreed credit period can constitute a separate international transaction under the Explanation to section 92B and be independently benchmarked for arm's length interest. The agreed credit period formed part of the commercial arrangement, but once payment remained outstanding beyond that period and no interest was charged, the receivables were treated as separately taxable for transfer pricing purposes. The contention that working capital adjustment had already absorbed the receivables impact was rejected on the facts, including the magnitude of the outstanding dues and the absence of a demonstrated working capital claim. The interest adjustment was upheld. en-us Mon, 06 Jul 2020 00:00:00 +0530 Mon, 28 Dec 2020 16:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=396951 Delayed realisation of trade receivables from an associated enterprise beyond the agreed credit period can constitute a separate international transaction under the Explanation to section 92B and be independently benchmarked for arm's length interest. The agreed credit period formed part of the commercial arrangement, but once payment remained outstanding beyond that period and no interest was charged, the receivables were treated as separately taxable for transfer pricing purposes. The contention that working capital adjustment had already absorbed the receivables impact was rejected on the facts, including the magnitude of the outstanding dues and the absence of a demonstrated working capital claim. The interest adjustment was upheld. Case-Laws Income Tax Mon, 06 Jul 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=396951