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    <title>2021 (5) TMI 208 - ITAT HYDERABAD</title>
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    <description>Delayed receivables from associated enterprises were treated as an international transaction for transfer pricing purposes, and the notional interest adjustment was upheld because the assessee had itself furnished the working and sought a lower interest rate. The Form 26AS tax credit mismatch required factual verification to ensure the same income was not taxed twice, so the matter was accepted for verification. A disallowance under section 14A read with Rule 8D could not be added back while computing book profit under section 115JB, and the MAT adjustment was deleted.</description>
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      <description>Delayed receivables from associated enterprises were treated as an international transaction for transfer pricing purposes, and the notional interest adjustment was upheld because the assessee had itself furnished the working and sought a lower interest rate. The Form 26AS tax credit mismatch required factual verification to ensure the same income was not taxed twice, so the matter was accepted for verification. A disallowance under section 14A read with Rule 8D could not be added back while computing book profit under section 115JB, and the MAT adjustment was deleted.</description>
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