TaxTMI 
TaxTMI 
2019 (8) TMI 606
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.... Aggrieved by the Order dated 27.01.2016 passed by the Ld. Assessing Officer, New Delhi, M/s BTR packaging private limited ("Assessee") preferred this appeal. 2. Brief facts of the case are that the assessee was incorporated on 18/07/2005 as 100% export oriented unit and has been engaged in manufacturing and exporting of high-quality polyethylene retail carrier bags, including merchandise bags, b....
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....PO, however, passed an order dated 22/01/2015 by suggesting adjustment under section 92 CA of the Income Tax Act, 1961 ("the Act") to the tune of Rs. 5,27,706/-in respect of the interest on receivables outstanding. 5. The assessee f iled objections before the Ld. Dispute Resolution Panel ("DRP"). Ld. DRP directed that the interest on receivables has to be computed in accordance with the decision ....
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....i. 7. Ld. DR placed reliance on the orders of the authorities below. 8. We have gone through the record in the light of the submissions made on either side. It remains an undisputed fact that the assessee had adopted TNMM method for determining the arm's length price for principal amount of exports to AE and it was duly accepted by the Ld. TPO. No adjustment under section 92 CA of the Act was su....
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....d by the assessee to use Accounts Receivable to have free working capital funding; and that if the impact of extended credit period on working capital was factored in the pricing / profitability, then there is no tax leakage or evasive tactics adopted by the taxpayer while transacting with the AE. With this view of the matter, we find it difficult to countenance the argument that, had the funds be....