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Proportionate adjustment for third-party transactions not given ...


TP Adjustment: Proportionate adjustment for third-party transactions remitted for computation. Notional interest on receivables deleted following precedent.

Case Laws     Income Tax

July 9, 2024

Proportionate adjustment for third-party transactions not given effect by AO/TPO as directed by DRP. Matter remitted to AO for computational purposes only. Notional interest on outstanding receivables deleted following stare decisis, as issue decided in assessee's favor in earlier years and Delhi High Court left question open regarding transfer pricing adjustment applicability to debt-free company. Authorities' orders set aside on this issue.

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