2023 (3) TMI 31

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....m Kumar, Sr. D.R. For the Respondent : Shri Vartik Choksi, A.R. & Shri Dhrunal Bhatt, A.R. ORDER PER Ms. SUCHITRA KAMBLE - JM: This appeal is filed by the Revenue against the order dated 21.11.2017 passed by the Ld. CIT(Appeals)-2, Ahmedabad for A.Y. 2012- 13. 2. The grounds of appeal raised by the Revenue read as under: "1. The Ld. CIT(A) has erred in law in deleting the u....

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....ent of Rs. 1,50,75,015/- towards notional interest made in respect of the outstanding receivables. The Ld. D.R. submitted that the ALP interest that was required to be charged by the assessee company from the AEs in view of delay in realization of sale invoices issued beyond the credit period extended by the assessee company. The Ld. D.R. pointed out Page 35 of the Assessment Order wherein the dur....

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....given a detail finding that the copy of invoices clearly shows that terms of delivery and payment is 180 days from the date of appeal of lading. Therefore, interest is not to be charged up to outstanding period less than 180 days. The CIT(A) has further observed that the TPO has charged interest for 335 days which is not correct but at the same time the TPO has rightly applied the rate at 3.05% wh....