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Income Tax - Highlights / Catch Notes

Home Highlights September 2022 Year 2022 This

TP adjustment - upward adjustment in imputing notional interest ...


No Extra Adjustment Needed for Outstanding Receivables in Transfer Pricing Case; ALP Already Accounts for Working Capital.

September 14, 2022

Case Laws     Income Tax     AT

TP adjustment - upward adjustment in imputing notional interest on the outstanding overdue receivables from Associated Enterprises - working capital adjustments on the ALP has been already factored in its pricing / profitability vis-à-vis that of its comparables - any further adjustment to the margin of the assessee on the outstanding receivables cannot be justified and no separate upward adjustment on outstanding export receivables is required - AT

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