Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
TP Adjustment - Interest on delayed receivables - The ITAT found that the conditions laid down by previous rulings, specifically in the case of PCIT vs. Kusum Healthcare, were met, justifying the inclusion of interest on delayed receivables as a separate international transaction. The Tribunal emphasized the need for proper inquiry by the Transfer Pricing Officer (TPO) over time to identify patterns indicating benefits to AEs, and rejected the appellant's argument that the receivables' impact was already considered in the working capital adjustment.
TP Adjustment - Interest on delayed receivables - The ITAT found that the conditions laid down by previous rulings, specifically in the case of PCIT vs. Kusum Healthcare, were met, justifying the inclusion of interest on delayed receivables as a separate international transaction. The Tribunal emphasized the need for proper inquiry by the Transfer Pricing Officer (TPO) over time to identify patterns indicating benefits to AEs, and rejected the appellant's argument that the receivables' impact was already considered in the working capital adjustment.
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