O R D E R

PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER:

The cross appeals have been filed by the Assessee and the Revenue against the order passed by the Ld. Commissioner of Income Tax (Appeals)-13, (in short “Ld. CIT(A)”), Ahmedabad vide orders dated 10.07.2025, 11.07.2025 & 15.07.2025 passed for A.Ys. 2014-15 to 2017-18. Since common facts and issues for consideration are involved for all years under consideration before us, all appeals are being disposed of by way of a common order.

2. The Assessee has raised the following grounds of appeal:

ITA No. 1845/Ahd/2025 (A.Y. 2014-15)

“1. Ground No 1- Upward adjustment of INR 8,70,342 in respect of notional interest on outstanding receivable.

1.1. On the facts and in the circumstances of the case and in low, the Hon'ble CIT(A) has erred in confirming the upward adjustment of INR 8,70,362 to the total income of the Appellant proposed by the learned Transfer Pricing Officer (learned "TPO') in respect of notional interest on outstanding receivables from Associated Enterprises (‘AES’).

1.2. On the facts and in the circumstances of the case and in law, the Hon'ble CIT(A)/learned TPO has erred in not appreciating the fact that outstanding receivable is not an international transaction, per se, under section 92B of the Act but an integral part of the primary transaction of sale of goods to AEs and cannot be seen in isolation.

1.3. On the facts and in the circumstances of the case and in law, the Hon’ble CIT (A) / learned TPO has erred in re-characterizing outstanding receivable as loan financing transactions.

1.4. On the facts and in the circumstances of the case and in law, the Hon'ble CTT(A)/learned TPO has erred in facts and circumstances of the case and in law, in disregarding the fact that working capital adjustment takes into account the impact of outstanding receivables on the profitability and therefore, no further imputation of interest is warranted.

1.5. On the facts and in the circumstances of the case and in law, the Hon'ble CIT(A)/learned TPO has erred in not appreciating the fact that charging interest on the outstanding receivables amounts to levying notional income and not real income.

1.6. On the facts and in the circumstances of the case and in law, the Hon'ble CIT(A)/learned TPO has erred in not appreciating the fact that the Appellant is a debt free company and hence adjustment of notional interest income is unwarranted.

The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before hearing of the appeal.

All the grounds of appeal stated above are without prejudice to each other.”

ITA No. 1846/Ahd/2025 (A.Y. 2015-16)

“1. Ground No 1- Upward adjustment of INR 89,49,166 in respect of notional interest on outstanding receivable.

1.1. On the facts and in the circumstances of the case and in low, the Hon'ble CIT(A) has erred in confirming the upward adjustment of INR 89,49,166 to the total income of the Appellant proposed by the learned Assessing Officer (learned "AO') in respect of notional interest on outstanding receivables from Associated Enterprises (‘AES’).

1.2. On the facts and in the circumstances of the case and in law, the Hon’ble CIT(A) has erred in not adjudicating the ground of appeal wherein the Appellant contended that the Transfer Pricing adjustment made by the learned AO is without jurisdiction, as the learned AO is not vested with the authority to determine the Arm’s Length Price of an international transaction.

1.3. On the facts and in the circumstances of the case and in law, the Hon'ble CIT(A)/learned TPO has erred in not appreciating the fact that outstanding receivable is not an international transaction, per se, under section 92B of the Act but an integral part of the primary transaction of sale of goods to AEs and cannot be seen in isolation.

1.4. On the facts and in the circumstances of the case and in law, the Hon’ble CIT (A) / learned AO has erred in re-characterizing outstanding receivable as loan financing trans