Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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Separate transfer-pricing adjustment for notional interest on delayed trade receivables from associated enterprises is not warranted where the taxpayer is completely debt-free and bears no interest cost on borrowings, because delayed collection creates no additional financing burden. Debt-free status requires verification from financial statements and other relevant records. If verified, the adjustment for interest on outstanding receivables is deleted. This approach applies across the assessment years concerned.
Separate transfer-pricing adjustment for notional interest on delayed trade receivables from associated enterprises is not warranted where the taxpayer is completely debt-free and bears no interest cost on borrowings, because delayed collection creates no additional financing burden. Debt-free status requires verification from financial statements and other relevant records. If verified, the adjustment for interest on outstanding receivables is deleted. This approach applies across the assessment years concerned.
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