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Outstanding receivables from associated enterprises, where they arose from sales transactions already benchmarked under TNMM and a working capital adjustment had been granted, did not justify a separate notional interest adjustment absent evidence of an independent financing arrangement; the adjustment was deleted. CSR-linked donations were not automatically barred from deduction merely because they were made in discharge of CSR obligations, but the claim required verification of recipient eligibility and other statutory conditions, so the matter was remitted. Grounds challenging initiation of penalty proceedings were treated as premature because no final penalty order was under appeal. The treaty-based claim for refund of excess dividend distribution tax was also restored for fresh adjudication.
Outstanding receivables from associated enterprises, where they arose from sales transactions already benchmarked under TNMM and a working capital adjustment had been granted, did not justify a separate notional interest adjustment absent evidence of an independent financing arrangement; the adjustment was deleted. CSR-linked donations were not automatically barred from deduction merely because they were made in discharge of CSR obligations, but the claim required verification of recipient eligibility and other statutory conditions, so the matter was remitted. Grounds challenging initiation of penalty proceedings were treated as premature because no final penalty order was under appeal. The treaty-based claim for refund of excess dividend distribution tax was also restored for fresh adjudication.
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