https://www.taxtmi.com/caselaws?id=421050 The Tribunal allowed the appeal filed by the assessee, directing the deletion of the addition made on the ground of enhancing income by interest on receivables from Associated Enterprise without granting a working capital adjustment. The Tribunal held that the Transactional Net Margin Method already considered notional interest costs, eliminating the need for a separate upward adjustment for delayed payments on receivables. The Tribunal also rejected the re-characterization of overdue receivables as an unsecured interest-free loan and the application of the Comparable Uncontrolled Price method for determining arm's length interest, emphasizing that TNMM adequately accounted for notional interest costs. en-us Thu, 31 Mar 2022 00:00:00 +0530 Sat, 16 Apr 2022 09:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=421050 The Tribunal allowed the appeal filed by the assessee, directing the deletion of the addition made on the ground of enhancing income by interest on receivables from Associated Enterprise without granting a working capital adjustment. The Tribunal held that the Transactional Net Margin Method already considered notional interest costs, eliminating the need for a separate upward adjustment for delayed payments on receivables. The Tribunal also rejected the re-characterization of overdue receivables as an unsecured interest-free loan and the application of the Comparable Uncontrolled Price method for determining arm's length interest, emphasizing that TNMM adequately accounted for notional interest costs. Case-Laws Income Tax Thu, 31 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=421050