https://www.taxtmi.com/caselaws?id=384323 The High Court considered whether notional amounts could be attributed in income and adjusted in Arm's Length Price (ALP) determination under Section 92CA(3) of the Income Tax Act. The Court held that notional income from delayed payments should not be subject to adjustments, referencing relevant case law. As no advanced amounts were involved in the case and the adjustments were based on the Transfer Pricing Officer's assessments, notional interest recovery was deemed inapplicable. Consequently, the Court dismissed the Revenue's appeals, finding them lacking merit. en-us Mon, 29 Jul 2019 00:00:00 +0530 Sat, 10 Aug 2019 06:48:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=384323 The High Court considered whether notional amounts could be attributed in income and adjusted in Arm's Length Price (ALP) determination under Section 92CA(3) of the Income Tax Act. The Court held that notional income from delayed payments should not be subject to adjustments, referencing relevant case law. As no advanced amounts were involved in the case and the adjustments were based on the Transfer Pricing Officer's assessments, notional interest recovery was deemed inapplicable. Consequently, the Court dismissed the Revenue's appeals, finding them lacking merit. Case-Laws Income Tax Mon, 29 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=384323