https://www.taxtmi.com/caselaws?id=429762 Transfer pricing comparables in the manufacturing segment had to match the assessee's earlier accepted factual matrix, so the disputed comparables were excluded and the arm's length price was recomputed. Delayed receivables could be treated as an international transaction, but notional interest had to be freshly benchmarked under transfer pricing principles, so the matter was remanded for recomputation. Secondment reimbursements on a cost-to-cost basis, with salary tax already deducted and no income element, were not fees for technical services and section 195 did not apply, so the related disallowance was deleted. Interest under section 234A could be levied only after verifying delay in filing the return. en-us Mon, 31 Oct 2022 00:00:00 +0530 Fri, 04 Nov 2022 08:52:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=429762 Transfer pricing comparables in the manufacturing segment had to match the assessee's earlier accepted factual matrix, so the disputed comparables were excluded and the arm's length price was recomputed. Delayed receivables could be treated as an international transaction, but notional interest had to be freshly benchmarked under transfer pricing principles, so the matter was remanded for recomputation. Secondment reimbursements on a cost-to-cost basis, with salary tax already deducted and no income element, were not fees for technical services and section 195 did not apply, so the related disallowance was deleted. Interest under section 234A could be levied only after verifying delay in filing the return. Case-Laws Income Tax Mon, 31 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429762