← All Phrases

“interest on outstanding receivables”

Transfer PricingSection 92BSection 92B244 judgments

The decision most relied on for interest on outstanding receivables is CIT v. EKL Appliances Ltd. (345 ITR 241), cited in 422 judgments on BharatTax.

Leading authorities on interest on outstanding receivables

CIT v. EKL Appliances Ltd.
345 ITR 241 · 2012 · High Court
422
citing judgments

Transfer pricing adjustments for outstanding receivables are permissible only if the Tax Officer establishes, through analysis over a period, a pattern indicating an international transaction intended to benefit an associated enterprise. The Tax Officer cannot question purely business decisions like royalty payments or exceed jurisdiction by applying cost-benefit analysis to determine the arm's length price of services.

CIT v. Cotton Naturals (I) (P.) Ltd.
55 Taxmann.com 523 · 2015 · High Court
273
citing judgments

The interest rate for benchmarking foreign currency loans advanced to Associated Enterprises should be the market-determined rate applicable to the currency of the loan, such as LIBOR for US Dollar loans, rather than a domestic lending rate like the Indian PLR.

Pr. CIT v. Kusum Health Care Pvt. Ltd.
398 ITR 66 · 2017 · High Court
100
citing judgments

Not every item of receivables appearing in the accounts of an entity dealing with foreign associated enterprises automatically constitutes an international transaction under Section 92B. A separate adjustment for interest on outstanding receivables is not permissible if the working capital adjustment has already factored in their impact.

CIT v. Patni Computer Systems Ltd.
215 Taxmann 108 · 2013 · High Court
92
citing judgments

The provision of an extended credit period or non-charging of interest on delayed receivables from associated enterprises constitutes an international transaction under Section 92B(1) and requires separate benchmarking at arm's length, even retrospectively due to the Finance Act, 2012 amendment.

Avenue Asia Advisors Pvt. Ltd. v. DCIT
398 ITR 120 · 2017 · High Court
84
citing judgments

The Delhi High Court holds that a detailed functional and working capital analysis, considering various factors, is essential before treating outstanding receivables as a separate international transaction for transfer pricing adjustments on notional interest. Simply making an adjustment based on receivables alone without such study distorts the transaction's character.

348 (Mum.); Tata Autocomp Systems Ltd. v. Asstt. CIT
21 Taxmann.com 6 · 2012 · ITAT
49
citing judgments

The use of LIBOR is upheld for benchmarking loans or advances given to foreign Associated Enterprises (AEs), and notional interest is to be computed using LIBOR rates for transfer pricing adjustments on amounts receivable from AEs.

Kusum Healthcare (P.) Ltd. v. Asstt. CIT
62 Taxmann.com 79 · 2015 · High Court
44
citing judgments

Interest cannot be separately charged on outstanding receivables from an associated enterprise if these receivables are an integral part of the underlying international transaction for which the arm's length price has already been determined. Such outstanding receivables are not considered a distinct international transaction.

CIT v. Indo American Jewellery Ltd.
44 Taxmann.com 310 · 2014 · High Court
42
citing judgments

A transfer pricing adjustment for notional interest on delayed receivables from an Associated Enterprise (AE) may not be warranted if the assessee consistently does not charge interest from both AEs and non-AEs.

Judgments citing interest on outstanding receivables

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

Vermeiren India Rehab Private Limited, Tirupati vs. DCIT., Circle-1(1), Tirupati

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1315/HYD/2024[2021-22]Status: DisposedITAT Hyderabad19 Nov 2025AY 2021-22

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: Sri Sandeep Bagmar R, AdvocateFor Respondent: MS. U. Mini Chandran, CIT-DR
Section 143(3)Section 144C(5)Section 32

LIBOR, and using LIBOR would not align with the economic realities of the Indian market. As a result, the DRP directed that, the interest on outstanding receivables be recomputed using SBI PLR. The Learned Counsel for the Assessee submitted that, the authorities below are erred in applying SBI rate instead

Sap India Private Limited, Bangalore vs. Jurisdictional Assessing Officer - Deputy Commissioner of Income Tax Circle 6(1)(1), Bangalore

The appeal of the assessee is allowed to the extent indicated above

ITA 1519/BANG/2024[2020-21]Status: DisposedITAT Bangalore17 Nov 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Soundararajan K, Jm

Section 143Section 144BSection 144C

comparability analysis. He submits that unjustifiable the working capital adjustments is denied to the assessee. With respect to the claim of the interest on outstanding receivables, the learned authorised representative has stated that receivables should be net of against the payables from its associated enterprises and the net amount should ... case in ITA No. 874 and 875/Bangalore/2022 for assessment year 2017 – 18 and 2018 – 19. Therefore, it is submitted that that interest on outstanding receivables should be adjusted 1st against the outstanding payable and then only the working of overdue receivable should be made. 12. The learned CIT DR vehemently

Rockwell Automation India Private Limited, Delhi vs. DCIT Circle-19(1), Delhi

Appeal is partly allowed for statistical purposes

ITA 3861/DEL/2024[2020-21]Status: DisposedITAT Delhi17 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalrockwell Automation India Deputy Commissioner Of Private Limited, Income Tax, Circle-19(1), Registered Address: 131, Vs. Delhi. Functional Industrial Are, Patparganj, Delhi-110092 Communication Address: 131, Functional Industrial Area, Patparganj, New Delhi. Pan-Aaccr3791A (Appellant) (Respondent) Assessee By Shri Ajit Jain, Ar Department By Shri Dharm Veer Singh, Cit-Dr Date Of Hearing 19.08.2025 Date Of Pronouncement 17.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Final Assessment Order Passed U/S 143(3) R.W.S 144C (13) Read With Section 144B Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 30.07.2024 For Assessment Year 2020-21. 2. Brief Facts Of The Case Ae That The Assessee Is A Company Engaged In The Business Of Manufacturing / Assembling Of Automation & Industrial Control Products / Systems. The Case Was Selected For Scrutiny & A Reference Was Made To The Tpo Due With Transactions With Ae’S. The Return Of Income Was Filed On Rockwell Automation India Private Limited Vs. Dcit 15.02.2021 Declaring Total Income At Rs.97,08,46,360/-. The Tpo Vide Its Order Dated 28.07.2023 Passed U/S 92Ca(3) Of The Act Has Proposed Adjustments Totaling To Rs. 26,12,44,668/-. Thereafter, The Ao Has Passed The Draft Assessment Order U/S 144C(1) Of The Act Dated 27.09.2023 Wherein The Ao Has Proposed The Additions Towards The Tp Adjustment As Per Tpo’S Order & Proposed To Assess The Total Income Of The Assessee At Rs.19,88,57,458/- & Further Proposed To Disallow Relief Claimed U/S 90/90A At Rs.1,04,60,287/-. Against The Draft Assessment Order, The Assessee Filed Objections Before The Drp.

Section 143(3)Section 144BSection 144C(1)Section 144C(10)Section 144C(13)Section 144C(8)Section 90Section 90ASection 92C

following:- (i) Distribution Segment - 8,43,18,133 (ii) Business Support Services Segment – 1,69,10,011 (iii) Interest on outstanding receivables – 42,28,704 2.2 The AO have than passed the final assessment order on 30.07.2024 u/s 143(3) r.w.s. 144C(13) r.w.s. 1444B of the Act wherein after ... Revenue erred in arbitrarily applying a markup of 400 basis points on 6 months LIBOR for the purpose of computing notional interest on outstanding receivables. Pertaining to corporate tax matters Erroneous addition of INR 2,92,79,876 in relation to the income computation and disclosure standards (ICDS) which

M/S.Ibs Software Services P. Ltd, Trivandrum vs. The DCIT, Trivandrum

ITA 601/COCH/2017[2013-14]Status: DisposedITAT Cochin13 Nov 2025AY 2013-14

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajakannan, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144CSection 144C(5)Section 36(1)(iii)Section 36(1)(va)Section 92C

notional interest on loans/advances. 5.4. Adopting identical reasoning, the TPO also proposed transfer pricing adjustment of INR.29,24,87,928/- in respect of interest on outstanding receivables [INR.167,37,50,666/- x 17.475%]. Before the TPO the Assessee had contended that no notional interest was required to be imputed ... Assessee was following a consistent policy of not charging interest on outstanding receivables from AEs & non-AEs, and (b) the primary transaction was benchmarked and accepted by the TPO as being at arm’s length. 5.5. The Assessing Officer incorporated the above transfer pricing adjustments on account of notional interest

Concur Technologies (India) Private Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle 2(2)(1), Bangalore

Appeal of the assessee is partly allowed as indicated above

ITA 2550/BANG/2024[2021-22]Status: DisposedITAT Bangalore11 Nov 2025AY 2021-22

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2021-22

For Appellant: Shri Chavali Narayan, CAFor Respondent: Dr Divya K J, CIT(DR)(ITAT), Bengaluru
Section 144Section 144BSection 144C

raised to the AEs. Further, the learned AO/ TPO has not appreciated the Page 7 of 20 fact that the Appellant neither charges interest on outstanding receivables from external vendors do not get charged on delayed payments to creditors. 10.6.The learned AO/ TPO erred in facts by not appreciating

Dgs Technical Services Private Limited, Hyderabad vs. DCIT., Circle-8(1), Hyderabad

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1095/HYD/2024[2021-22]Status: DisposedITAT Hyderabad31 Oct 2025AY 2021-22

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

Section 143(3)Section 144C(5)Section 92C

deposits with it. 4 DGS Technical Services Private Limited 13. Without prejudice, the Ld TPO/Ld AO/Ld DRP ought to have appreciated that the Interest on outstanding receivables ought to have been charged at LIBOR plus 200 basis points. 14. The assessee craves leave to add, amend, omit, substitute the above ... interest on 9 DGS Technical Services Private Limited outstanding receivables from the A.E., on the ground that, the Ld. TPO has rightly computed interest on outstanding receivables from the A.E. by adopting SBI short-term deposit rate, which is an index rate adopted under Indian conditions to charge interest

DCIT Central Circle-1(1), Mumbai vs. S Vinodkumar Diamonds Private Limited, Mumbai

Accordingly, Ground No.1 & 2 raised by the Revenue are treated as allowed for statistical purpose

ITA 2282/MUM/2025[2012-13]Status: DisposedITAT Mumbai27 Oct 2025AY 2012-13

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Vartik ChoksiFor Respondent: Shri Pravin Salunkhe
Section 143(3)(ii)Section 144C(3)Section 14ASection 92B

under: “The assessee's submission and facts of the case have been carefully considered. It is seen that the appellant does not charge interest on outstanding receivables both from AEs and Non AEs. Also the assessee does not pay interest on outstanding payables to both AEs and Non AEs. This ... receivable holding that it is a separate international transaction. The learned CIT (A) held that the learned Assessing Officer is correct in charging interest on outstanding receivable from Associated Enterprises. He further held that for A.Y. 2009-10, the learned CIT (A) has confirmed identical addition. On the issue

DCIT Central Circle-1(1), Mumbai vs. S Vinodkumar Diamonds Private Limited, Mumbai

Accordingly, Ground No.1 & 2 raised by the Revenue are treated as allowed for statistical purpose

ITA 2281/MUM/2025[2013-14]Status: DisposedITAT Mumbai27 Oct 2025AY 2013-14

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Vartik ChoksiFor Respondent: Shri Pravin Salunkhe
Section 143(3)(ii)Section 144C(3)Section 14ASection 92B

under: “The assessee's submission and facts of the case have been carefully considered. It is seen that the appellant does not charge interest on outstanding receivables both from AEs and Non AEs. Also the assessee does not pay interest on outstanding payables to both AEs and Non AEs. This ... receivable holding that it is a separate international transaction. The learned CIT (A) held that the learned Assessing Officer is correct in charging interest on outstanding receivable from Associated Enterprises. He further held that for A.Y. 2009-10, the learned CIT (A) has confirmed identical addition. On the issue

Schneider Electric Private Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle 22(2), C. R. Building, Delhi

The appeal is allowed partly

ITA 5589/DEL/2024[2021-22]Status: DisposedITAT Delhi15 Oct 2025AY 2021-22

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2021-22 Schneider Electric Private Vs Dcit, Limited, Circle 22(2), C-56, Mayapuri Industrial Area, Delhi. Phase-2, West Delhi, Delhi – 110 064. Pan: Abacs1671F (Appellant) (Respondent) Assessee By : Shri Rohit Tiwari, Advocate & Ms Tanya, Advocate. Revenue By : Shri S.K. Jadhav, Cit-Dr Date Of Hearing : 20.08.2025 Date Of Pronouncement : 15.10.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Final Assessment Order Dated 28.10.2024 Passed By The Assessment Unit, Income-Tax Department (Hereinafter Referred To As The Ld. Ao) U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For Ay 2021-22. 2. Heard & Perused The Records. On The Basis Of Submission & Material On Record It Comes Up That Assesse/ Appellant (Sepl) Was Incorporated In 2018 As A Subsidiary Of Schneider Electric Industries Sas (A Wholly Owned Subsidiary Of Schneider Electric Se) & Belgium. It Is A Private Limited Company

For Appellant: Shri Rohit Tiwari, Advocate &For Respondent: Shri S.K. Jadhav, CIT-DR
Section 143(3)

Appellant and the margin of the tested party is within the arm’s length range, no separate adjustment is warranted on account of interest on outstanding receivables from AEs in the hands of the Appellant. Reliance in this regard is placed in the case of Kusum Healthcare

Tupperware India Private Limited, Connaught Place New Delhi vs. National Faceless Assessment Centre Through Deputy Commissioner of Income Tax, Ip Estate New Delhi

The appeal is allowed partly

ITA 4475/DEL/2024[2020-21]Status: DisposedITAT Delhi15 Oct 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year : 2020-21

Section 143(3)Section 37Section 92BSection 92C

cause as to why certain adjustments (inter alia payment of alleged AMP expenses and payment of royalty, payment of management service fees and interest on outstanding receivables) should not be undertaken by the Ld. TPO. 5. During the year under consideration, the Assessee was engaged in manufacturing and distribution ... Advertising, 5,35,18,215 Marketing and Promotion (AMP) [Substantive basis] 2. Management service fee paid to AE 2,91,45,590 3. Interest on outstanding receivables 2,66,196 Total 8,29,30,001 7. Now with regard to TP adjustments ld. AR has submitted that the issues

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 partly allowed for statistical purposes

ITA 2346/BANG/2024[2021-22]Status: DisposedITAT Bangalore10 Oct 2025AY 2021-22

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

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 ... that on the 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. 34.1 We also refer the decision of this Tribunal in the case

DCIT, Circle - 3(1), Visakhapatnam vs. Snf India Private Limited, Visakhapatnam

ITA 209/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Ravish Sood, Hon'Ble & Shri S Balakrishnan, Hon'Bleआयकर अपीलसं./I.T.A.No.204/Viz/2025 (निर्धारणवर्ष/ Assessment Year:2016-17) M/S. Snf (India) Private Limited 19 Jnpc, Ramky Pharmacity Paravada, Visakhapatnam – 531021 Andhra Pradesh [Pan:Aaacp4070A] Vs. Dcit - Circle – 3(1) Income Tax Office Infinity Towers, Sankarmat Road Visakhapatnam – 530016 Andhra Pradesh आयकर अपीलसं./I.T.A.Nos.209 & 210/Viz/2025 (निर्धारणवर्ष/ Assessment Years:2016-17 & 2014-15) Dcit - Circle – 3(1) 35,50-92-35, Sankaramatam Road Opposite Reliance Fresh, Beside Reliance Fresh, Nearby Main Road Madhuranagar, Dwarakanagar Visakhapatnam – 530016 Vs. M/S. Snf (India) Private Limited Plot No. 19 Ponnuru Village, Parawada Mandal Visakhapatnam – 531021 Andhra Pradesh [Pan:Aaacp4070A] करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/Date Of Pronouncement Shri Kanchan Kaushal, Ca Shri Badicala Yadagiri, Cit(Dr) 01.09.2025 08.10.2025

Section 142(1)Section 143(2)Section 92C

international transaction directed the Ld. AO / Ld.TPO to Page. No 6 I.T.A.Nos.204, 209 & 210/VIZ/2025 M/s. SNF (India) Private Limited recompute the interest on outstanding receivable by adopting LIBOR + 200 basis points as against 7.5% adopted by the TPO. Finally, on the issue of upward adjustment of Rs.39

Jubilant Generics Ltd., Noida vs. ACIT, Circle- 5(1)(1), G.B. Nagar

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

ITA 2004/DEL/2022[2018-19]Status: DisposedITAT Delhi24 Sept 2025AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

Section 143(3)Section 144BSection 92C

determining arm's length price of the impugned transaction ITA No. 2004/Del/2022 Jubilant Generics Ltd. Grounds of appeal with respect to Notional interest on outstanding receivables from AEs On the facts and in the circumstances of the case under law, the CA AO/TPO/DRP erred by treating receivables from ... Plintron Global Technology Solutions Pvt. Ltd. TS-238-ITAT-2018(CHNY)-TP, has held that the LIBOR is more appropriate for computing interest on outstanding receivables from AEs. In arriving at its decision, the ITAT relied on the ruling of the Mumbai Bench of the ITAT in the case

Agilent Technologies (International) Private Limited, Manesar, Gurgaon vs. The Deputy Commissioner of Income Tax Circle 1(1), Gurgaon

In the result, the appeal of the assessee is allowed

ITA 3684/DEL/2024[2020-21]Status: DisposedITAT Delhi17 Sept 2025AY 2020-21

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2020-21 Agilent Technologies Vs. Dcit, (International) Private Limited, Circle 1(1), Plot No.Cp-11, Sector 8, Imt, Gurgaon Manesar, (Haryana) Gurgaon - 122051 Aadca4115C (Appellant) (Respondent)

For Appellant: S/Shri Mayank Khannam, Akhil GoelFor Respondent: Shri Dharm Veer Singh, CIT (DR)
Section 142(1)Section 143(2)Section 143(3)Section 144C(13)Section 19Section 21Section 92C

paperbook volume 1 for the ITAT order for AY 2010-11 to AY 2012-13) has deleted the adjustment on account of interest on outstanding receivables. 6. Learned Authorised Representative for the Department of Revenue submitted that the Ld.TPO had taken into consideration documents pertaining to three years. I Services ... deleted the entire adjustment with respect to SDS segment and has reduced the adjustment in the ITeS segment and adjustment made pertaining to interest on outstanding receivables. Appellant filed rectification application dated 13.08.2024 at page 232 and 238 of paper books against final assessment order. 7.1 Ld. TPO took

Technip India Limited, New Delhi vs. ACIT, Spl Range-9, New Delhi

In the result, Appeal No.6390/Del/2017 is partly allowed as per above terms

ITA 9852/DEL/2019[2015-16]Status: DisposedITAT Delhi17 Sept 2025AY 2015-16

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 6390/Del/2017 Assessment Year: 2013-14 Ita No. 9852/Del/2019 Assessment Year: 2015-16 Technip Energies India Vs. Additional Commissioner Of Limited, ( Formerly Known As Income Tax, Technip India Limited), Special Range-9, A-4, Sector 1, Institutional New Delhi Area, Noida – 201 301 Pan No. Aaack3349R (Appellant) (Respondent)

For Appellant: Shri Vishal Kalra, Adv., Shri Yishu GoelFor Respondent: Shri Dharm Veer Singh, CIT (DR)
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 250Section 92C

also advocated the approach of aggregation of closely inextricably connected transactions for the purpose of benchmarking. 8.4 Margin of Appellant even after excluding interest on outstanding receivables much higher than the margin earned by comparable companies. The net margin of the Appellant after excluding the interest on outstanding receivables works ... comparable companies is 9.58%. Therefore, it is established that the Appellant has earned a much higher margin even after excluding the interest on outstanding receivables and thus there should be no Transfer Pricing adjustment on account of the detailed payment. Cases where it has been held that where assessee

Technip India Ltd., Noida vs. Addl.CIT, Special Range- 9, New Delhi

In the result, Appeal No.6390/Del/2017 is partly allowed as per above terms

ITA 6390/DEL/2017[2013-14]Status: DisposedITAT Delhi17 Sept 2025AY 2013-14

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 6390/Del/2017 Assessment Year: 2013-14 Ita No. 9852/Del/2019 Assessment Year: 2015-16 Technip Energies India Vs. Additional Commissioner Of Limited, ( Formerly Known As Income Tax, Technip India Limited), Special Range-9, A-4, Sector 1, Institutional New Delhi Area, Noida – 201 301 Pan No. Aaack3349R (Appellant) (Respondent)

For Appellant: Shri Vishal Kalra, Adv., Shri Yishu GoelFor Respondent: Shri Dharm Veer Singh, CIT (DR)
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 250Section 92C

also advocated the approach of aggregation of closely inextricably connected transactions for the purpose of benchmarking. 8.4 Margin of Appellant even after excluding interest on outstanding receivables much higher than the margin earned by comparable companies. The net margin of the Appellant after excluding the interest on outstanding receivables works ... comparable companies is 9.58%. Therefore, it is established that the Appellant has earned a much higher margin even after excluding the interest on outstanding receivables and thus there should be no Transfer Pricing adjustment on account of the detailed payment. Cases where it has been held that where assessee

D. E. Shaw India Private Limited, Hyderabad vs. DCIT., Circle-8(1), Hyderabad

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

ITA 1154/HYD/2024[2020-21]Status: DisposedITAT Hyderabad12 Sept 2025AY 2020-21

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1154/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2020-21) M/S. D.E. Shaw India Pvt. Dy. Commissioner Of Income Vs. Ltd., Hyderabad. Tax, Pan:Aaacd7214J Circle 8(1), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.P. Chidambaram, Adv. रधजस् व द्वधरध/Revenue By: Ms. U. Mini Chandran, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 01/09/2025 घोर्णध की तधरीख/Pronouncement: 12/09/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By M/S. D E Shaw India Pvt. Ltd. (“The Assessee”), Feeling Aggrieved By The Assessment Order Passed By The Learned Assessing Officer (“Ld. Ao”) U/S. 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (“The Act”) Dated 27.06.2024 For The A.Y. 2020-21. 2. At The Outset, It Is Seen That There Is A Delay Of 66 Days In Filing Of The Present Appeal, For Which The Assessee Has Filed Condonation Petition Explaining The Reasons For Delay In Filing Of The Appeal. As Per Record, The Appeal Was Required To Be Filed On Or Before

For Appellant: Shri S.P. Chidambaram, AdvFor Respondent: Ms. U. Mini Chandran, SR-DR
Section 143(3)

AO/TPO to give effect to the working capital adjustment while computing margins and, thereafter, not to make any separate benchmarking adjustment towards interest on outstanding receivables. ITA No.1154/Hyd/2024 19 18. As regards the last argument of the assessee that it is a debt- free company, we observe that once

ACIT-6(1)(1), Mumbai vs. M/S Essar Power Limited, Mumbai

In the result, the appeal by the Revenue is partly allowed

ITA 4395/MUM/2025[2015-16]Status: DisposedITAT Mumbai11 Sept 2025AY 2015-16

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalassistant Commissioner Of Income Tax- 6(1)(1), Room No.504, 5Th Floor, Aaykar Bhavan, Churchgate, ............... Appellant Mumbai - 400020 V/S M/S. Essar Power Limited, 11Th Floor Essar House, 11 K.K. Marg, ……………… Respondent Mahalaxmi, Mumbai - 400034 Pan : Aaace0895J Assessee By : Shri Vijay Mehta Revenue By : Ms. Neena Jeph, Cit-Dr

For Appellant: Shri Vijay MehtaFor Respondent: Ms. Neena Jeph, CIT-DR
Section 14ASection 250Section 92C

issue arising in Grounds No.1 and 2, raised in Revenue’s appeal, pertains to the transfer pricing adjustment on account of interest on outstanding receivables from the associated enterprises. 5. The brief facts of the case pertaining to this issue are that the assessee is a part of the Essar ... that the assessee has shown outstanding receivables from its associated enterprises. Accordingly, the assessee was asked to show cause as to why the interest on outstanding receivable should not be charged. In response, the assessee submitted that the outstanding receivables from Essar Africa Holding Limited are not a separate international

Lowes Services India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle 4(1)(1), Bangalore

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

ITA 1734/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore08 Sept 2025

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2020-21

For Appellant: Shri Chavali Narayan, ARFor Respondent: Dr. Divya K J, CIT(DR)(ITAT), Bengaluru
Section 143(1)Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 36(1)(va)Section 80G

against the returned income of INR 78,61,52,120/-. Grounds relating to Transfer pricing matters: 3. Adjustment on account of interest on outstanding receivables amounting to INR 1,98,60,669/-. 3.1 The Ld. AO/ TPO/ DRP grossly erred in determining a transfer pricing adjustment on account ... interest on outstanding receivables amounting to INR 1,98,60,669/-. Without prejudice to our ground of objection 3.1 above, the Ld. AO/TPO/DRP erred in law and in facts: Page 3 of 15 a) By not appreciating that the outstanding trade receivables from AEs are arising from provision of software