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Mckinsey Knowledge Centre India Pvt. ... vs Dcit Circle 16(1) , Delhi on 4 June, 2024 cites

Alcatel Lucent India Ltd., Gurgaon vs Acit, Circle-1(1), New Delhi on 16 August, 2021

D. The assessee has also relied on the decision of Hon 'ble Delhi IT A T in the case of Aicatel Lucent India Ltd. vs. ACIT (2023) 149 taxmann.com 150 (Delhi Tribunal). In this connection, it is respectfully submitted that in the subsequent assessment year i.e. for A.Y. 2018-19, the Hon'ble Delhi ITAT vide its order in ITA 0 1447/Del/2022 dated 20.03.2024 has after discussing its own order for A.Y. 2017-18 has taken a contrary view and has restored the matter to the AO. Being pertinent, the operative part of the decision is reproduced below:-
Income Tax Appellate Tribunal - Delhi Cites 20 - Cited by 3 - Full Document

Vi Micro Systems P Ltd., Chennai vs Acit, Chennai on 29 August, 2017

Even otherwise, as rightly held by the Logix Micro Systems Ltd v. ACIT [42 SOT 525] (supra), TPO should have allowed some interest free period for receiving the outstanding service charges. While acknowledging the order of the ITAT, TPO did not even bother to exclude the reasonable period and levied interest not only from the date of invoice to the date of realization during the year but also for the period beyond 31-03-2010 in later year. We were informed that no such addition was made in the later year on Assessee's 11 ITA No.475/DEL/2022 receivables. We are of the opinion that both on the facts of the case and principles of law, there is no need for bringing to tax the notional interest on the outstanding receivables. Accordingly, we allow the grounds 7 & 8 of Assessee and direct AOITPO to delete the said addition made. "
Income Tax Appellate Tribunal - Chennai Cites 12 - Cited by 51 - Full Document

M/S.Sundaram Fin.Ltd vs Asst.Commissioner Of Income ... on 11 September, 2012

has been considered to be an international transaction which is required to be benchmarked. Following the above said Explanation, the co-ordinate Bench for the subsequent assessment years vide order dt.16-5-2017 in the case of Bechtel India (P.) Ltd. v. Asstt. CIT [2017} 85 taxmann.com 121 (Delhi - Trib.) had decided the issue against the assessee. In view of the above, the decision relied upon by the assessee is of no help to assessee.
Supreme Court of India Cites 3 - Cited by 237 - Full Document

Eli Lilly And Company India Pvt. Ltd., ... vs Dcit, Circel-1(1), Gurgaon on 14 October, 2019

C. The assessee has also relied on the decision of Hon 'ble Delhi High Court in the case of Kusum Healthcare. From the perusal of the records, it is seen that though the TPO has mentioned the invoices raised during the year but ha evident from the DRP directions, it is clearly evident that this issue of interest on delayed receivables is recurring issue and additions have been made on notional interest in earlier years also in the case of 20 ITA No.475/DEL/2022 assessee and accordingly, it clearly reflects a pattern which is spread over several years and it fulfils the condition laid down in Kusum Healthcare decision. Also, it is respectfully submitted that the decision of Kusum Healthcare has been distinguished by several Tribunals across the country and it has been held consistently that working capital adjustment does not subsume the invoices raised and realised during the year as adjustment are made only at the• end of the year based on the opening and closing figure. This has been discussed in several cases including
Income Tax Appellate Tribunal - Delhi Cites 26 - Cited by 0 - Full Document
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