https://www.taxtmi.com/caselaws?id=413699 HC dismissed the Department's challenge and upheld exclusion of the identified fund manager from the comparable set, finding its functions and risk profile materially different from the assessee as previously decided in favour of the assessee. The court also rejected a one-sided notional interest adjustment for delayed receivables where many invoices were paid in advance, holding it impermissible to compute interest on alleged delays while ignoring advances; factually, advances exceeded late receipts. The broader question of applying such transfer-pricing adjustments to a debt-free company was left open. en-us Tue, 12 Oct 2021 00:00:00 +0530 Sat, 27 Sep 2025 10:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=413699 HC dismissed the Department's challenge and upheld exclusion of the identified fund manager from the comparable set, finding its functions and risk profile materially different from the assessee as previously decided in favour of the assessee. The court also rejected a one-sided notional interest adjustment for delayed receivables where many invoices were paid in advance, holding it impermissible to compute interest on alleged delays while ignoring advances; factually, advances exceeded late receipts. The broader question of applying such transfer-pricing adjustments to a debt-free company was left open. Case-Laws Income Tax Tue, 12 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=413699