Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
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Delayed recovery of associated enterprise receivables was held not to justify a working capital transfer pricing adjustment where the branch was debt-free, had no borrowings or interest claim, and its working capital needs were funded by head office, so no opportunity cost or borrowed-funds assumption was shown. The Tribunal therefore found no basis to interfere with deletion of the adjustment. Interest under section 234D was treated as consequential, and that ground was accepted on the assessee's concession.
Delayed recovery of associated enterprise receivables was held not to justify a working capital transfer pricing adjustment where the branch was debt-free, had no borrowings or interest claim, and its working capital needs were funded by head office, so no opportunity cost or borrowed-funds assumption was shown. The Tribunal therefore found no basis to interfere with deletion of the adjustment. Interest under section 234D was treated as consequential, and that ground was accepted on the assessee's concession.
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