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Income Tax - Highlights / Catch Notes

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TP adjustment - Arms’ length price of international transaction ...


Arms' Length Price for Overdue Export Proceeds Set at Nil Due to Equal Treatment of Enterprises.

January 3, 2023

Case Laws     Income Tax     AT

TP adjustment - Arms’ length price of international transaction of overdue export proceeds - non-charging of interest on advances being overdue export proceeds from Associated Enterprises as a comparable internal CUP as for similar time on similar conditions, for almost similar period no interest is charged from Non Associated Enterprises - In view of this, we find that Arms Length Price of overdue Export proceeds and receivable from Associated Enterprises is ₹ Nil. - AT

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