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TMI Blog2021 (5) TMI 356X X X X Extracts X X X X X X X X Extracts X X X X ..... s filed by the assessee against the final assessment of the Ld. Deputy Commissioner of Income Tax, Circle-3(1), passed U/s. 143(3) r.w.s. 144C(13) of the Act, dated 30/07/2018 for the A.Y. 2014-15. 2. The assessee has raised several grounds in its appeal however, the cruxes of the issues are that:- (i) The ld. Members of the DRP have erred in confirming the order of the lower authorities who ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt was completed u/s. 143(3) 144C(13) of the Act on 30/07/2018 wherein the ld. AO made the above mentioned additions. 4. Ground No. 1: Arm's Length Price Adjustment of Rs. 99,626/- towards notional interest on receivables from Associated Enterprises: 5. At the outset, the Ld. AR submitted that the Ld. Revenue Authorities have added the notional interest on receivables from the assessee's ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... AR. Since, the transactions are cross-border, it would be appropriate to adopt LIBOR rate of interest while computing the notional interest on receivables from the AEs. This Bench of the Tribunal has held so on various earlier occasions with respect to the same issue. Further, it will also be appropriate for netting off the notional interest with respect to the debit and credit transaction with th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m-3CD. Even before us, the assessee has not substantiated that the expenditure was incurred for the purpose of the assessee's business. Hence, we hereby confirm the addition made for Rs. 2,41,139/- by the ld. AO. 9. Ground No.: 3: Adhoc disallowance of Rs. 10 lakh towards expenditure incurred on freight and Rs. 2 lakhs towards expenditure incurred on repairs: 10. On verifying the Bills and V ..... X X X X Extracts X X X X X X X X Extracts X X X X
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