Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
Non-debit of partners' remuneration and interest did not affect eligibility for deduction under section 10AA where the resulting business profit remained eligible, so the deletion of the addition was justified. The note also records that reassessment cannot travel beyond the recorded reasons: reopening was based on discrepancy in import figures, no addition was made on that issue, and the addition on partners' remuneration and interest was outside the permissible scope. The Revenue's appeal was dismissed on both grounds.
Non-debit of partners' remuneration and interest did not affect eligibility for deduction under section 10AA where the resulting business profit remained eligible, so the deletion of the addition was justified. The note also records that reassessment cannot travel beyond the recorded reasons: reopening was based on discrepancy in import figures, no addition was made on that issue, and the addition on partners' remuneration and interest was outside the permissible scope. The Revenue's appeal was dismissed on both grounds.
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