DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. CCL PRODUCTS (INDIA) LIMITED, GUNTUR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A. No.97/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2011-12) Deputy Commissioner Of Income V. Ccl Products (India) Limited, Tax, Guntur-522330, Guntur-522004. Andhra Pradesh. Pan: Aaacc9552G (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

92B by Finance Act, 2012 if there is any delay in realization of a trading debt arising from sale of goods or services rendered in course of carrying on of business, assessee is liable for transfer pricing adjustment on account of interest income short charged / uncharged as held by Hon’ble Delhi High Court in the case of MCkinsey Knowledge

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

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

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.340/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2020-21) & S.A. No. 15/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2020-21) Teejay India Private Limited, Vs. Deputy Commissioner Of Plot No. 15, Brandix, Apsez, Income Tax, Pudimadaka Road, Atchutapuram Circle-5(1), Mandal, Visakhapatnam-530011. Visakhapatnam. Pan: Aaaco9452H (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

disallowing an amount of Rs. 23,47,826/- towards amortization of leasehold rights. Grounds for imputation of notional interest on outstanding receivables. 1. On the facts and in the circumstances of the case, the Ld. DRP/AO/TPO erred in : 1.1. Considering overdue receivables from AEs as an international transaction under the provisions of section 92B

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, DC/AC 4(1), VISAKHAPATNAM

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

section 92B of the Act. 7.2. Without prejudice to Ground No.7.1 above, 7.2.1 ignoring the fact that the appellant does not pay interest in relation to outstanding payable to AEs 7.3.Without prejudice to the ground No. 7.1 and 7.2 above, the Ld. DRP erred in providing notional credit period of 30 days as provided

GVK POWER AND INFRASTRUCTURE LIMITED,JEGURUPADU vs. DCIT, CIRCLE-1, RAJAHMUNDRY

In the result, appeal of the assessee is partly allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

section 92B of the Act, in the instant case it cannot be disputed to be an international transaction. The contention of the Ld. AR is against the benchmarking @ 7% on the outstanding guarantee commission receivable. The Ld. AR also demonstrated that the AE is in financial difficulties and hence the assessee has subscribed the preference share capital issued

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

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

section 92B of the Act. While deciding on the identical issue the ITAT in the case of M/s. Devi Sea Foods Limited vs. DCIT in ITAT No.75/Viz/2022, dated 9/9/2022, held as follows: “7……….There is no dispute with regard to the fact that receivables is included under the definition of international transaction consequent to the amendments made by the Finance