https://www.taxtmi.com/caselaws?id=178390 Notional interest on delayed export receivables could not be added as a transfer pricing adjustment where the assessee treated associated enterprise and non-associated enterprise debtors uniformly and did not charge interest from either class. The appellate findings showed that the delay in realisation of export proceeds was the same across both categories, so no differential benefit or profit shifting outside India was established. On those facts, the proposed adjustment lacked a sustainable basis and was deleted in favour of the assessee. en-us Tue, 08 Jan 2013 00:00:00 +0530 Mon, 25 Aug 2025 14:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178390 Notional interest on delayed export receivables could not be added as a transfer pricing adjustment where the assessee treated associated enterprise and non-associated enterprise debtors uniformly and did not charge interest from either class. The appellate findings showed that the delay in realisation of export proceeds was the same across both categories, so no differential benefit or profit shifting outside India was established. On those facts, the proposed adjustment lacked a sustainable basis and was deleted in favour of the assessee. Case-Laws Income Tax Tue, 08 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178390