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Income Tax - Highlights / Catch Notes

Home Highlights July 2021 Year 2021 This

Transfer Pricing Adjustment - Adjustment on account of notional ...


Court Rules Notional Interest on Receivables Invalid Without Legal Mandate for Debt-Free Companies Under Transfer Pricing.

July 22, 2021

Case Laws     Income Tax     AT

Transfer Pricing Adjustment - Adjustment on account of notional interest on the receivables - when the assessee is having their own funds and not paying interest on any loans, then there is no obligation on the assessee to charge interest from the interest free loan given nor any provision of the Act mandate the Assessing Officer to add notional interest received to the total income - the assessee being a debt free company, the action of the revenue making adjustment on account of notional interest on the receivables cannot be held to be legally valid. - AT

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