https://www.taxtmi.com/caselaws?id=399320 The Tribunal upheld the CIT(A)'s decision to recharacterize outstanding account receivables as unsecured loans, requiring compensation for extended credit to Associated Enterprises in the form of interest. The Tribunal rejected the appellant's arguments on working capital adjustment profitability results, internal Comparable Uncontrolled Price (CUP) for benchmarking, and notional interest on account receivables. It affirmed the application of LIBOR + 300 basis points for calculating interest on outstanding receivables, emphasizing the separate international transaction nature of outstanding receivables beyond the agreed period. en-us Tue, 06 Oct 2020 00:00:00 +0530 Thu, 08 Oct 2020 11:46:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=399320 The Tribunal upheld the CIT(A)'s decision to recharacterize outstanding account receivables as unsecured loans, requiring compensation for extended credit to Associated Enterprises in the form of interest. The Tribunal rejected the appellant's arguments on working capital adjustment profitability results, internal Comparable Uncontrolled Price (CUP) for benchmarking, and notional interest on account receivables. It affirmed the application of LIBOR + 300 basis points for calculating interest on outstanding receivables, emphasizing the separate international transaction nature of outstanding receivables beyond the agreed period. Case-Laws Income Tax Tue, 06 Oct 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=399320