Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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Where the Department's remand report accepted the assessee's explanation on notional interest, ad hoc disallowance of expenses, and addition of trade payables, there was no basis to sustain any addition. The ITAT found no reason to interfere with the CIT(A)'s deletion of the additions relating to notional interest on interest-free advances to a subsidiary, power, fuel, administrative and repair ? Wait no. Use English. and trade payables, and upheld the deletion of all disputed adjustments.
Where the Department's remand report accepted the assessee's explanation on notional interest, ad hoc disallowance of expenses, and addition of trade payables, there was no basis to sustain any addition. The ITAT found no reason to interfere with the CIT(A)'s deletion of the additions relating to notional interest on interest-free advances to a subsidiary, power, fuel, administrative and repair ? Wait no. Use English. and trade payables, and upheld the deletion of all disputed adjustments.
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