https://www.taxtmi.com/caselaws?id=300602 The Tribunal ruled in favor of the appellant regarding Arm's Length Price (ALP) adjustments on interest receivables in international transactions, directing the Transfer Pricing Officer to delete the adjustment due to lack of comparables and market practice analysis. However, the appellant's argument that interest on receivables should not be treated as an international transaction under Explanation(c) to Section 92B of the Income Tax Act was rejected, as the department had applied the Explanation retrospectively. The appeal was partly allowed based on these findings. en-us Wed, 19 May 2021 00:00:00 +0530 Tue, 15 Feb 2022 06:56:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=300602 The Tribunal ruled in favor of the appellant regarding Arm's Length Price (ALP) adjustments on interest receivables in international transactions, directing the Transfer Pricing Officer to delete the adjustment due to lack of comparables and market practice analysis. However, the appellant's argument that interest on receivables should not be treated as an international transaction under Explanation(c) to Section 92B of the Income Tax Act was rejected, as the department had applied the Explanation retrospectively. The appeal was partly allowed based on these findings. Case-Laws Income Tax Wed, 19 May 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=300602