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“interest on outstanding receivables”

Transfer PricingSection 92BSection 92B244 judgments

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

ITA 1842/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

Section 250

ld.CIT(A) was justified in not appreciating the findings of TPO by deleting the upward adjustment made on account of charging of interest on outstanding receivables given to its AEs by the assessee company. 5) Whether on the facts and the circumstances of the case ... transfer pricing adjustment. Accordingly, Ground Nos. 1 & 2 raised by the Revenue are dismissed. Ground Nos. 3 & 4 – Upward Adjustment on Account of Interest on Outstanding Receivables 5. The above grounds relate to the deletion of upward adjustment made by the TPO/AO by charging notional interest on outstanding receivables from

PARAMETRIC TECHNOLOGY (INDIA) PRIVATE LIMITED,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(2), BENGALURU

In the result, the appeal of the assessee is partly allowed

ITA 2514/BANG/2024[2021-22]Status: DisposedITAT Bangalore24 Feb 2026AY 2021-22
For Appellant: Shri Darpan Kirpalani, CAFor Respondent: Dr. Divya K.J, CIT (DR)
Section 143(3)

diverted borrowed funds for the benefit of its associated\nenterprises. Accordingly, the Ld. AR prayed that the impugned\nadjustment on account of notional interest on outstanding receivables be\ndeleted.\n18.3 On the other hand, the Ld. DR before us submitted that the\noutstanding receivables from associated enterprises constitute a\nseparate

M/S. NTT DATA GLOBAL SERVICES PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 5, BANGALORE

ITA 2533/BANG/2019[2015-16]Status: DisposedITAT Bangalore23 Feb 2026AY 2015-16
Section 133(6)Section 143(3)Section 144C(13)Section 144C(5)

directions of the Hon'ble DRP erred, in\nlaw and facts, in determining separate transfer pricing adjustment\non account of the interest on outstanding receivables amounting to\nINR 72,817,000\n10.\nWithout prejudice to our ground of appeal no. 9 above. Ld. AO/TPO\npursuant to the directions

DCIT-13(1)(1), MUMBAI vs. M/S ORACLE FINANCIAL SERVICES SOFTWARE LTD., MUMBAI

In the result, appeal of the revenue stands partly allowed and\nappeal of the assessee stands allowed

ITA 3995/MUM/2019[2008-09]Status: DisposedITAT Mumbai19 Feb 2026AY 2008-09
Section 14A

nbusinesses. The Ld.AR emphasized that no interest was charged by\nthe assessee to third-party customers for any delay in payments and, notional interest on outstanding receivables from the subsidiaries. He submitted that the longer outstanding period was, inter alia, the result of the US-AE\nnot having collected amounts

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(1), VISAKHAPATNAM

ITA 533/VIZ/2024[2021-22]Status: DisposedITAT Visakhapatnam18 Feb 2026AY 2021-22

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 143(1)Section 143(3)Section 144C(1)Section 92C

respect of payment of interest on ECB and INR 86,54,646 on account of imputation of notional interest on outstanding receivables. Further, the learned AO and the learned DRP erred in disallowing an amount of INR 23,47,826 towards amortization of leasehold rights.” 2. Succinctly stated, the assessee ... assessee’s paper book (APB). Elaborating on his contention, the Ld. AR submitted that the Tribunal, regarding the issue of imputation of notional interest on outstanding receivables, had based on identical facts as were involved in the case before them for the aforementioned preceding years, drawn support from its earlier

ZS ASSOCIATES INDIA PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE -12,, PUNE

In the result, appeal of the assessee is dismissed as withdrawn

ITA 211/PUN/2022[2017-18]Status: DisposedITAT Pune05 Feb 2026AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.211/Pun/2022 निर्धारण वषा / Assessment Year: 2017-18 Zs Associates India Private V The Additional / Joint / Limited, S Deputy / Assistant Tower 3, World Trade Centre, Commissioner Of Kharadi, Pune – 411014. Income Tax, Dcit, Circle-12, Pune. Pan:Aaacz2157Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Ninad Patade (Through Virtual) Revenue By Shri Prakash L Pathade Date Of Hearing 11/12/2025 Date Of Pronouncement 06/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Assessee Has Filed An Appeal Against The Assessment Order Dated 16.02.2022 Passed U/S.143(3) R.W.S 144C(13) Read With Section 144B Of The Act, 1961 For The A.Y.2017- 18, Emanating From Order Of The Dispute Resolution Panel U/S.144C(5) Of The Act, Dated 06.12.2021, Which In Turn Emanates From Draft Assessment Order U/S.143(3) R.W.S 144C(1) Of The Act

Section 143(3)Section 144Section 144BSection 144C(5)

applying any of the prescribed methods as per Section 92C(1) of the Act while determining the arm's length price of the interest on outstanding receivables. Deduction in respect of 'Education Cess on income-tax', while computing the total income of the Appellant 4.1 The learned AO/Hon

TE CONNECTIVITY INDIA PRIVATE LIMITED,BANGALORE vs. THE OFFICE OF THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 7(1)(1), BANGALORE

In the result, the appeal of the assessee is hereby partly allowed

ITA 1789/BANG/2024[2020-21]Status: DisposedITAT Bangalore08 Jan 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Darpan Kriplani, CAFor Respondent: Dr. KJ Dhivya, CIT (DR)

amendment to section 92B of the Act by way of Finance Act, 2012 with retrospective effect from 01/04/2002 that, the interest on outstanding receivables is an international transaction, and it certainly requires separate benchmarking. Accordingly, the extended credit period or credit allowed over and above the agreed period shall

ERM INDIA PRIVATE LIMITED,GURUGRAM vs. ASSESSMENT UNIT (JAO- DCIT, CIRCLE 7(1), DELHI), DELHI

In the result, this appeal is partly allowed

ITA 5459/DEL/2024[2021-22]Status: DisposedITAT Delhi07 Jan 2026AY 2021-22

Bench: Shriyogesh Kumar Us & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.5459/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Erm India Private Limited, Assessment Unit, 3Rd Floor, Tower B, Building No.10, Vs. Income Tax Department, Dlf Cyber City, Phase-Ii, (Jurisdictional Ao: Deputy Gurugram, Haryana. Commissioner Of Income-Tax), Pan No.Aaace1502C Circle 7(1), Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 144C(13)Section 253(1)(d)Section 92B

interest at 15.25 per cent (SBI PLR @ 12.25% plus 300 basis points) and calculated an adjustment of INR 1,80,07,955 as interest on outstanding receivables. 1.5 Aggrieved by the order of Ld. TPO, the Appellant preferred to file objections before ... giving effect to Hon’ble DRP’s directions the transfer pricing adjustment was reduced to INR 75,65,322. 2 Ground No 2 - Interest on Outstanding Receivables Key contention of ERM • Principal transaction has been accepted to be at ALP by the Ld. TPO - The net cost-plus margin earned

GIESECKE AND DEVRIENT INDIA PVT LTD.,GURGAON vs. ACIT (OSD), NEW DELHI

In the result, assessee’s appeal in ITA No

ITA 1428/DEL/2022[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Ms. Madhumita Roy & Smt. Renu Jauhriassessment Year: 2018-19

Section 119Section 143(3)Section 144BSection 144B(8)Section 144C(13)Section 144C(5)

income of the Appellant on account of alleged difference in the arm's length price of the alleged international transaction of interest on outstanding receivables 35. That the TPO/AO/DRP erred on facts and in law by considering the continuing debit balance of receivables of the Appellant as a separate "international ... from third parties. 37. That the DRP/TPO ought to have considered that as a commercial decision the Appellant is neither levying nor charging interest on outstanding receivable from AE's as well as the third parties. 38. The TPO/AO erred in applying 'substance over form' principle to re- characterizing

SHAKTI HORMANN PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD

ITA 917/HYD/2024[2020-21]Status: DisposedITAT Hyderabad19 Dec 2025AY 2020-21

Bench: Shri Manjunatha G.\Nand\Nshri Ravish Sood\Nआ.अपी.सं /Ita No.917/Hyd/2024\N(निर्धारण वर्ष/Assessment Year:2020-21)\Nshakti Hormann Private\Nlimited,\Nhyderabad.\Nvs. Dcit,\Ncircle-3(1),\Nhyderabad.\Npan: Aadcs4024Q\N(Appellant)\N(Respondent)\Nनिर्धारिती द्वारा / Assessee By: Shri P. Murali Mohan Rao,\Nca\Nराजस्व द्वारा / Revenue By: Ms. U. Mini Chandran,\Ncit-Dr\Nसुनवाई की तारीख /Date Of Hearing: 15/10/2025\Nघोषणा की तारीख / Date Of 19/12/2025\Npronouncement:\Nआदेश / Order\Nper. Ravish Sood, J.M:\Nthe Present Appeal Filed By The Assessee Company Is Directed\Nagainst The Final Assessment Order Passed By The Assessing Officer (For\Nshort, “A.O.”) Under Section 143(3) R.W.S 144C(13) R.W.S 144B Of The\Nincome Tax Act, 1961 (For Short, “The Act”) Dated 25/07/2024 For The\N Assessment Year (Ay) 2020-21. The Assessee Company Has Assailed\Nthe Impugned Order Passed By The Cit(A) On The Following Grounds Of\Nappeal Before Us:\N1. On The Facts & In The Circumstances Of The Case, The Final Assessment\Norder Passed U/S 143(3) R.W.S.144C(13) Of The Act Dated 25.07.2024 By\Nthe Ao & Also The Order Passed U/S 92Ca (3) Dt 30.07.2023 By The Tpo\Nare Bad In The Eyes Of Law & Thus, Unsustainable To The Test Of Appeal.\N2.0 The Final Assessment Order Passed U/S 143(3) R.W.S.144C(13) R.W.S.144B\Nis Beyond The Time Limit Prescribed U/S 153 Of The Act.\N2.

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Ms. U. Mini Chandran
Section 143(3)Section 153Section 92C

that outstanding receivables\nare linked to the sale of services to the AE during the normal course of\nbusiness and that charging of interest on outstanding receivables is\nunwarranted.\n5.8 The Ld. AO ought to have appreciated that interest on receivables\ncannot be coined as separate international transaction as envisaged

SWATCH GROUP (INDIA) RETAIL PRIVATE LIMITED,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 4281/DEL/2024[2020-21]Status: DisposedITAT Delhi12 Dec 2025AY 2020-21

Bench: Shri S.Rifaur Rahman & Ms. Madhumita Royswatch Group (India) Retail Private Ltd., Vs. Dcit, Circle 22(2), 4Th Floor, Rectangle 1, Plot No.D4, Delhi. Saket District Centre, Saket, New Delhi – 110 017. (Pan : Aavcs7960H) (Appellant) (Respondent) Assessee By : Shri Ravi Sharma, Advocate Ms. Shruti Khimta, Ar Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 16.09.2025 Date Of Order : 12.12.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 26.07.2024 Passed By The Assessment Unit, Income Tax Department Under Section 143(3) Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :-

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 92C(3)Section 92D

TPO/Ld. AO erred on facts and in law in making an adjustment amounting to INR 15,67,140 on account of alleged notional interest on outstanding receivables due from Associated Enterprises. In doing so: 3.1 The Ld. TPO/Ld. AO erred on facts and in law in identifying the outstanding receivables ... TPO/Ld. AO erred on facts and in law erred in considering the outstanding receivables of INR 2,99,78,103 for computing interest on outstanding receivables instead of INR 2,96,69,975; 3.5 Without prejudice to above grounds, the Ld. TPO/Ld. AO erred in not giving effect

COSMO FILMS LTD.,NEW DELHI vs. DCIT, CIRCLE- 6(2), NEW DELHI

In the result, the appeal filed by the assessee is allowed

ITA 7849/DEL/2017[2013-14]Status: DisposedITAT Delhi12 Dec 2025AY 2013-14

Bench: Shri S.Rifaur Rahman & Ms. Madhumita Roycosmo Films Limited, Vs. Dcit, Circle 6 (2), 1008, Dlf Tower A, New Delhi. Jasola District Centre, New Delhi – 110 025. (Pan : Aaacc1152C) (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate Shri Somil Aggarwal, Advocate Shri Deepesh Garg, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 18.09.2025 Date Of Order : 12.12.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 27.10.2013 Passed By The Dcit, Circle 6 (2), Delhi Under Section 143(3) Read With Section 144C Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2013-14 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :-

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144CSection 144C(5)Section 92

facts of the case there was no cause or motive for the Appellant to shift profits out of India by not charging interest on outstanding receivables of its AEs. 2.3 That the Ld. AO/ DRP erred on facts and in law in not appreciating that notional interest on receivables does ... working capital. 2.7 Without prejudice to above, the Ld. DRP erred on facts and in law in not appreciating that even if the interest on outstanding receivables is to be considered as part of sale price of goods, it stands bench marked along with such transaction of sale of goods

ADP PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 1(1), HYDERABAD, TELANGANA

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 332/HYD/2025[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 195(2)Section 40

fresh economic analysis during the course of assessment proceedings, thereby making an adjustment to the international transaction relating to provision of services and interest on outstanding receivables. 6. Ground 6: Use of additional/modified filters 5 ADP Private Limited The Ld. TPO / Ld. AO / Hon'ble DRP erred in rejecting certain ... resulting in incorrect margins of the comparable companies and other computational errors to arrive at adjustment amount. 17. Ground 17: Interest on outstanding receivables The Ld. TPO and the Hon'ble DRP erred in: a) Not appreciating that outstanding receivables is not covered in the definition of international transaction

INDEED INDIA OPERATIONS PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE2(1), HYDERABAD

In the result, appeal of the Assessee for the assessment year 2021-2022 is allowed

ITA 943/HYD/2024[AY 2020-21]Status: DisposedITAT Hyderabad10 Dec 2025

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.943 & 1359/Hyd/2024 Assessment Years 2020-2021 & 2021-2022 Indeed India Operations The Acit, Private Limited, Vs. Circle-2(1), Hyderabad – 500 081. Hyderabad. Telangana Pan Aadci5931J (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Mahima Goud, Advocate राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Mahima Goud, AdvocateFor Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)Section 144BSection 144C(13)Section 153Section 92C(3)

Honourable Dispute Resolution Panel ('the Hon'ble DRP"), erred in making transfer pricing adjustment of INR 1,68,62,731 towards interest on outstanding receivables. 2. On the facts and in the circumstances of the case and in law, the Ld. TPO erred and the Hon'ble DRP further erred ... facts and circumstances of the case and in law, the addition made by the Ld. AO Ld. TPO with respect to interest on outstanding receivables is untenable and ought to be deleted since the addition has been made by computing interest on an invoice-to-invoice basis as against

INDEED INDIA OPERATIONS PRIVATE LIMITED,HYDERABAD vs. ACIT., CIRCLE -(1) , HYDERABAD

In the result, appeal of the Assessee for the\n

ITA 1359/HYD/2024[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22
Section 143(3)Section 144BSection 144C(13)Section 153Section 92C(3)

Honourable Dispute Resolution Panel ('the\nHon'ble DRP\"), erred in making transfer pricing adjustment of INR\n1,68,62,731 towards interest on outstanding receivables.\n2. On the facts and in the circumstances of the case and in law, the\nLd. TPO erred and the Hon'ble DRP further erred

NETCRACKER TECHNOLOGY SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 730/HYD/2024[AY 2020-21]Status: DisposedITAT Hyderabad03 Dec 2025

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 92C(3)

Honourable Dispute Resolution Panel ('the Hon'ble DRP'), erred in making transfer pricing adjustment of INR 4,56,91,941 towards interest on outstanding receivables and INR 2,09,59,025 on corporate tax issues, aggregating to INR 6,66,50,966, and the same being wholly unjustified are liable ... facts and circumstances of the case and contrary to law, the addition made by the L.d. AO/Ld. TPO with respect to interest on outstanding receivables is untenable and be deleted since the addition has been made by computing interest on an invoice-to-invoice basis as against on a weighted

BRIGHTCOM GROUP LIMITED (FORMERLY KNOWN AS LYCOS INTERNET LIMITED),HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(1),, HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 1862/HYD/2017[2013-14]Status: DisposedITAT Hyderabad03 Dec 2025AY 2013-14
Section 145Section 92BSection 92C

allow a reasonable credit period and make adjustment to outstanding receivables from AE only instead of total receivables while arriving at the interest on outstanding receivables. 1.2. Erred in re-characterizing the nature of transaction from 'Receivables' to 'loan' and charging interest which is not permissible

DCIT CIRCLE 1(1), NEW DELHI vs. ACME TELE POWER LTD. (NOW KNOWN AS ACME CLEANTECH SOLUTION LTD.), NEW DELHI

In the result, appeal of the Revenue is dismissed

ITA 1074/DEL/2023[2010-11]Status: DisposedITAT Delhi20 Nov 2025AY 2010-11

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

basis of adjustment proposed by the Ld. TPO on account of determination of Arm's Length Price for Interest on outstanding receivables and that too by applying external CUP method and further erred in observing that the outstanding receivables is a separate international transaction a per explanation ... assessee are with respect to the addition of INR 33,33,195/- made towards the transfer pricing adjustment on account of interest on outstanding receivables with AEs. 12. Before us, ld.AR of the assessee argued that the assessee has not charged any interest on outstanding balances of receivables from both

M/S. ACME CLEANTECH SOLUTIONS LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of the Revenue is dismissed

ITA 3641/DEL/2017[2011-12]Status: DisposedITAT Delhi20 Nov 2025AY 2011-12

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

basis of adjustment proposed by the Ld. TPO on account of determination of Arm's Length Price for Interest on outstanding receivables and that too by applying external CUP method and further erred in observing that the outstanding receivables is a separate international transaction a per explanation ... assessee are with respect to the addition of INR 33,33,195/- made towards the transfer pricing adjustment on account of interest on outstanding receivables with AEs. 12. Before us, ld.AR of the assessee argued that the assessee has not charged any interest on outstanding balances of receivables from both

M/S. ACME CLEANTECH SOLUTIONS LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, appeal of the Revenue is dismissed

ITA 4478/DEL/2016[2010-11]Status: DisposedITAT Delhi20 Nov 2025AY 2010-11

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

basis of adjustment proposed by the Ld. TPO on account of determination of Arm's Length Price for Interest on outstanding receivables and that too by applying external CUP method and further erred in observing that the outstanding receivables is a separate international transaction a per explanation ... assessee are with respect to the addition of INR 33,33,195/- made towards the transfer pricing adjustment on account of interest on outstanding receivables with AEs. 12. Before us, ld.AR of the assessee argued that the assessee has not charged any interest on outstanding balances of receivables from both

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