https://www.taxtmi.com/caselaws?id=456259 The ITAT Bangalore partially allowed the assessee's appeal regarding TP adjustment on receivables from AE. The TPO had treated receivables as international transaction and applied 13.675% interest rate using CUP method. Following precedent in Xchanging Solutions Ltd., the Tribunal held that receivables from software services to AE should allow 90 days credit period, with interest at LIBOR plus 300 basis points applicable only on delayed realization beyond 90 days. The TPO was directed to recompute ALP accordingly after providing hearing opportunity to assessee. en-us Wed, 11 Jan 2023 00:00:00 +0530 Wed, 10 Jul 2024 20:04:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456259 The ITAT Bangalore partially allowed the assessee's appeal regarding TP adjustment on receivables from AE. The TPO had treated receivables as international transaction and applied 13.675% interest rate using CUP method. Following precedent in Xchanging Solutions Ltd., the Tribunal held that receivables from software services to AE should allow 90 days credit period, with interest at LIBOR plus 300 basis points applicable only on delayed realization beyond 90 days. The TPO was directed to recompute ALP accordingly after providing hearing opportunity to assessee. Case-Laws Income Tax Wed, 11 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456259