https://www.taxtmi.com/caselaws?id=450932 The ITAT Delhi ruled on multiple issues involving a taxpayer's transfer pricing and expense allocation matters. Regarding interest on delayed receivables from associated enterprises, the tribunal held that such interest constitutes a separate international transaction requiring benchmarking, directing computation using LIBOR plus markup after setting off receivables cleared within 30 days. For wireless ports capitalization, the tribunal allowed 60% depreciation treating them as computer peripherals rather than the AO's 15% rate. On SEZ/non-SEZ expense allocation, the tribunal accepted the assessee's turnover-based allocation method, noting separate books were maintained and audited. The tribunal partially allowed the appeal, affirming some adjustments while modifying others based on proper allocation principles and transfer pricing regulations. en-us Tue, 05 Mar 2024 00:00:00 +0530 Fri, 15 Mar 2024 14:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450932 The ITAT Delhi ruled on multiple issues involving a taxpayer's transfer pricing and expense allocation matters. Regarding interest on delayed receivables from associated enterprises, the tribunal held that such interest constitutes a separate international transaction requiring benchmarking, directing computation using LIBOR plus markup after setting off receivables cleared within 30 days. For wireless ports capitalization, the tribunal allowed 60% depreciation treating them as computer peripherals rather than the AO's 15% rate. On SEZ/non-SEZ expense allocation, the tribunal accepted the assessee's turnover-based allocation method, noting separate books were maintained and audited. The tribunal partially allowed the appeal, affirming some adjustments while modifying others based on proper allocation principles and transfer pricing regulations. Case-Laws Income Tax Tue, 05 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450932