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    <title>Demurrage charges excluded from transfer pricing analysis as extraordinary costs, notional interest on receivables rejected</title>
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    <description>ITAT allowed the assessee&#039;s appeal regarding transfer pricing adjustments on two grounds. First, demurrage and detention charges of Rs. 2.57 crores constituted extraordinary costs and were non-operating in nature, given the exponential increase from previous years&#039; charges of Rs. 1.5 lakhs to Rs. 4.05 lakhs on lower turnovers. Excluding these charges brought the operating profit/operating cost ratio to 1.35%, within the arm&#039;s length price tolerance limit of 1.78%. Second, no notional interest could be charged on outstanding receivables of Rs. 10.91 crores from local parties transacting on behalf of the associated enterprise, considering the assessee was debt-free and receivables remained unpaid, following established precedent regarding notional interest charges.</description>
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    <pubDate>Thu, 03 Jul 2025 08:34:36 +0530</pubDate>
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      <title>Demurrage charges excluded from transfer pricing analysis as extraordinary costs, notional interest on receivables rejected</title>
      <link>https://www.taxtmi.com/highlights?id=90064</link>
      <description>ITAT allowed the assessee&#039;s appeal regarding transfer pricing adjustments on two grounds. First, demurrage and detention charges of Rs. 2.57 crores constituted extraordinary costs and were non-operating in nature, given the exponential increase from previous years&#039; charges of Rs. 1.5 lakhs to Rs. 4.05 lakhs on lower turnovers. Excluding these charges brought the operating profit/operating cost ratio to 1.35%, within the arm&#039;s length price tolerance limit of 1.78%. Second, no notional interest could be charged on outstanding receivables of Rs. 10.91 crores from local parties transacting on behalf of the associated enterprise, considering the assessee was debt-free and receivables remained unpaid, following established precedent regarding notional interest charges.</description>
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      <pubDate>Thu, 03 Jul 2025 08:34:36 +0530</pubDate>
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