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    <title>2020 (3) TMI 571 - ITAT DELHI</title>
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    <description>Notional interest adjustment on overdue receivables was unsustainable because, following the co-ordinate bench ruling in the assessee&#039;s own case, the assessee being a debt-free entity, no notional interest could be imputed; the adjustment was deleted. Addition for mismatch between Form 26AS and tax credit/revenue was held legally erroneous as s.68 is inapplicable to such reconciliation differences, and the AO failed to comply with DRP directions to add only the net difference after verification; the issue was remanded to the AO/TPO to examine reconciliation and delete any addition if reconciled. For TP comparables, entities functionally dissimilar to an ITES service provider were directed to be excluded; the matter was to be recomputed accordingly. Disallowance of car lease rentals u/s 40(a)(ia) was remanded to apply the second proviso retrospectively, subject to evidence that payees offered the receipts to tax.</description>
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    <pubDate>Fri, 17 Jan 2020 00:00:00 +0530</pubDate>
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      <title>2020 (3) TMI 571 - ITAT DELHI</title>
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      <description>Notional interest adjustment on overdue receivables was unsustainable because, following the co-ordinate bench ruling in the assessee&#039;s own case, the assessee being a debt-free entity, no notional interest could be imputed; the adjustment was deleted. Addition for mismatch between Form 26AS and tax credit/revenue was held legally erroneous as s.68 is inapplicable to such reconciliation differences, and the AO failed to comply with DRP directions to add only the net difference after verification; the issue was remanded to the AO/TPO to examine reconciliation and delete any addition if reconciled. For TP comparables, entities functionally dissimilar to an ITES service provider were directed to be excluded; the matter was to be recomputed accordingly. Disallowance of car lease rentals u/s 40(a)(ia) was remanded to apply the second proviso retrospectively, subject to evidence that payees offered the receipts to tax.</description>
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      <pubDate>Fri, 17 Jan 2020 00:00:00 +0530</pubDate>
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