https://www.taxtmi.com/caselaws?id=372440 The Tribunal found that the inclusion of inter-company receivables as international transactions was not feasible due to a retrospective amendment. It accepted the principle of "Impossibility of Performance" in this regard. Disagreeing with the re-characterization of receivables as loans, the Tribunal referenced precedent cases to support its decision. Ultimately, the appeal was allowed, ruling that the authorities were unjustified in adding the inter-company receivables amount. The order was pronounced on 20th December 2018. en-us Thu, 20 Dec 2018 00:00:00 +0530 Sat, 22 Dec 2018 08:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=372440 The Tribunal found that the inclusion of inter-company receivables as international transactions was not feasible due to a retrospective amendment. It accepted the principle of "Impossibility of Performance" in this regard. Disagreeing with the re-characterization of receivables as loans, the Tribunal referenced precedent cases to support its decision. Ultimately, the appeal was allowed, ruling that the authorities were unjustified in adding the inter-company receivables amount. The order was pronounced on 20th December 2018. Case-Laws Income Tax Thu, 20 Dec 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=372440