Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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Interest earned on fixed deposits compulsorily created under subsidy sanction conditions for a cold chain facility was held to have a direct nexus with the business activity, not to be income from other sources. On that basis, the Tribunal treated the interest as business income and held it eligible for deduction under section 80IB(11), deleting the disallowance. It also found the additions for savings bank interest and income-tax refund interest factually unsustainable, as no savings account existed in the assessee's name and no deduction had been claimed for refund interest. Those additions were deleted, and the appeal was allowed.
Interest earned on fixed deposits compulsorily created under subsidy sanction conditions for a cold chain facility was held to have a direct nexus with the business activity, not to be income from other sources. On that basis, the Tribunal treated the interest as business income and held it eligible for deduction under section 80IB(11), deleting the disallowance. It also found the additions for savings bank interest and income-tax refund interest factually unsustainable, as no savings account existed in the assessee's name and no deduction had been claimed for refund interest. Those additions were deleted, and the appeal was allowed.
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