https://www.taxtmi.com/caselaws?id=428940 The HC upheld the ITAT's findings that the assessee, being debt-free, cannot be presumed to have utilized borrowed funds to provide facilities to its AE, negating TP adjustment on receivables. The Court agreed there was no basis for disallowance under Section 40(a)(ia) as the assessee deducted TDS under Section 192, rendering Section 195 inapplicable for salary payments. The judgment in Centrica India Offshore Pvt. Ltd was held inapplicable since the Indian entity remained the real employer. The issues regarding receivables and Section 40(a)(ia) disallowance were deemed factual with no substantial question of law. The question concerning the draft order under Section 144(c)(1) issued in the name of a non-existent company was left open for future consideration. en-us Tue, 11 Oct 2022 00:00:00 +0530 Mon, 11 Aug 2025 18:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=428940 The HC upheld the ITAT's findings that the assessee, being debt-free, cannot be presumed to have utilized borrowed funds to provide facilities to its AE, negating TP adjustment on receivables. The Court agreed there was no basis for disallowance under Section 40(a)(ia) as the assessee deducted TDS under Section 192, rendering Section 195 inapplicable for salary payments. The judgment in Centrica India Offshore Pvt. Ltd was held inapplicable since the Indian entity remained the real employer. The issues regarding receivables and Section 40(a)(ia) disallowance were deemed factual with no substantial question of law. The question concerning the draft order under Section 144(c)(1) issued in the name of a non-existent company was left open for future consideration. Case-Laws Income Tax Tue, 11 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=428940