Sec. 92C – Transfer Pricing – SLP dismissed against order of HC that where debtor days given to non-AEs were more than debtor days given to AEs and assessee had net monthly balance payable to AEs as opposed to monthly balance receivables from non AEs, assessee was justified in not charging interest on delayed payments by AEs and in not levying any interest on delayed payments made by non-AEs.
PCIT v. Avery Dennison (I) (P.) Ltd. – [2023] 154 taxmann.com 455 (SC).