https://www.taxtmi.com/caselaws?id=456219 The dominant issue was whether interest on outstanding receivables from an AE constitutes a separate international transaction warranting a TP adjustment. Applying the binding ratio of HC that mere inclusion of "receivables" in the Explanation to s.92B does not automatically characterise every receivable as an international transaction, the Tribunal held that such characterisation must be context-specific. It further held that where the assessee has already accounted for receivables through working-capital adjustment in benchmarking against comparables, an additional interest adjustment would distort profitability and impermissibly recharacterise the transaction. Consequently, the TP adjustment/addition on interest on AE receivables was deleted and the appeal was allowed. en-us Fri, 09 Feb 2024 00:00:00 +0530 Thu, 08 Jan 2026 13:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456219 The dominant issue was whether interest on outstanding receivables from an AE constitutes a separate international transaction warranting a TP adjustment. Applying the binding ratio of HC that mere inclusion of "receivables" in the Explanation to s.92B does not automatically characterise every receivable as an international transaction, the Tribunal held that such characterisation must be context-specific. It further held that where the assessee has already accounted for receivables through working-capital adjustment in benchmarking against comparables, an additional interest adjustment would distort profitability and impermissibly recharacterise the transaction. Consequently, the TP adjustment/addition on interest on AE receivables was deleted and the appeal was allowed. Case-Laws Income Tax Fri, 09 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456219