TaxTMI 
TaxTMI 
2026 (4) TMI 1923
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....25 2. In the memo of appeal, the assessee has raised 04 grounds of appeal challenging the transfer pricing adjustment, which, we for the sake of brevity are not inclined to reproduced here. 3. At the outset, we note that ground Nos. 1 and 2 are general in nature and does not call for any specific adjudication. Accordingly, the same is dismissed as infructuous. 4. Ground Nos. 3 and 4 raised by assessee are interconnected and pertains to notional interest on trade receivables. 5. The facts of the case on hand are that the assessee, a private limited company, is engaged in the business of sale of interior and decoration related products. The assessee also renders SWD services to its holding company viz. Livspace Pte. Ltd. During th....
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....ever, the Ld. DRP regarding the contention of the assessee as to whether the interest on delayed receivables constitutes a separate international transaction, observed that the amendment inserted by way of Explanation to sec. 92B of the Act, the term 'internation transaction' would specifically include within its ambit "deferred payment or receivable or any other debt arising during course of business..." and hence, non-charging or under-charging of interest on excess period of credit allowed to the AE for the realization of invoices would amount to an international transaction. The Ld. DRP further relied on plethora of judicial precedents in this regard. The Ld. DRP further upheld the action of the ld. TPO in treating the interest on recei....
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....ave considered the rival submissions of both the parties and perused the materials available on record. The TPO has treated the outstanding trade receivables from AEs as a separate international transaction and computed interest thereon by adopting the LIBOR + 450 basis point rate. At the outset, regarding the contention of the assessee that the interest on delayed receivables should not be treated as a separate international transaction, we find that by virtue of the amendment inserted by way of Explanation to section 92B of the Act, the term "international transaction" has been expanded to specifically include within its ambit "deferred payment or receivable or any other debt arising during the course of business". Therefore, non-charging....