Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held that when TNMM is applied, the net margin already accounts for such notional interest costs. Thus, no separate adjustment for notional interest on receivables was warranted, and the tribunal directed the AO to delete the upward adjustment made for overdue receivables from AEs. - Further, Ld. AO / TPO directed to examine and consider the appropriate adjustments arising out of the working capital differences in the computation of the ALP.
TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held that when TNMM is applied, the net margin already accounts for such notional interest costs. Thus, no separate adjustment for notional interest on receivables was warranted, and the tribunal directed the AO to delete the upward adjustment made for overdue receivables from AEs. - Further, Ld. AO / TPO directed to examine and consider the appropriate adjustments arising out of the working capital differences in the computation of the ALP.
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TaxTMI 
TaxTMI 
of 4916 
