2024 (1) TMI 421

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....ssee : Shri Mohnish Saini, A.R. For the Revenue : Shri Rajesh Kumar, CIT(D.R.) ORDER PER PRADIP KUMAR KEDIA, AM : The captioned appeal has been filed by the assessee is challenging the final assessment order passed under section 143(3) read with section 144C(13) of the Income-tax Act, 1961 pertaining to Assessment Year 2017-18, in pursuance to the directions of learned Dispute Resoluti....

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....s from its AE's consistent with arm's length principles. In terms of the DRP direction, the matter was referred to the Transfer Pricing Officer (TPO). Based on the order of TPO, the Assessing Officer embarked upon transfer pricing adjustment to the tune of Rs. 6,63,370/- being interest on delayed payments from its AE's adopting SBI base rate plus 300 basis points. The transfer pricing adjustment w....

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....udice the cause of the Revenue. On this ground alone, the impugned adjustment requires to be cancelled. The ld. Counsel thereafter submitted that similar credit policies have been extended to unconnected entities. No interest has been charged to third party customers. Further, such impact of overdue receivables has already been factored and is already subsumed in the working capital adjustment. To....