https://www.taxtmi.com/caselaws?id=305715 The Appellate Tribunal upheld the Transfer Pricing Officer's decision to benchmark the Arms length price of an international transaction involving interest payment to Associated Enterprises at Nil. The Tribunal rejected the assessee's argument to aggregate the transaction with others using the TNMM, emphasizing the distinct nature of the transaction with Non Associated Enterprises and the presence of an internal Comparable Uncontrolled Price due to differing credit periods. Despite evidence of interest payments to AEs in previous years, the Tribunal maintained that it did not impact the benchmarking of the current transaction, ultimately dismissing the appeal. en-us Mon, 21 Mar 2022 00:00:00 +0530 Wed, 21 Dec 2022 14:39:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=305715 The Appellate Tribunal upheld the Transfer Pricing Officer's decision to benchmark the Arms length price of an international transaction involving interest payment to Associated Enterprises at Nil. The Tribunal rejected the assessee's argument to aggregate the transaction with others using the TNMM, emphasizing the distinct nature of the transaction with Non Associated Enterprises and the presence of an internal Comparable Uncontrolled Price due to differing credit periods. Despite evidence of interest payments to AEs in previous years, the Tribunal maintained that it did not impact the benchmarking of the current transaction, ultimately dismissing the appeal. Case-Laws Income Tax Mon, 21 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=305715