Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
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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