https://www.taxtmi.com/caselaws?id=438701 The Dispute Resolution Panel upheld the validity of reassessment proceedings under Section 147 of the Income Tax Act. The application of Section 92 was confirmed, with adjustments made for Arm's Length Price. The Transfer Pricing Officer's computation for ALP was reduced by the DRP. Deferred receivables were considered international transactions, with interest adjustments based on short-term deposit rates. The Tribunal directed a reevaluation of interest on outstanding receivables, applying a notional interest rate. The Tribunal remanded TP adjustment and trade receivables issues for fresh adjudication, partially allowing the appeal for statistical purposes. en-us Wed, 31 May 2023 00:00:00 +0530 Mon, 05 Jun 2023 12:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438701 The Dispute Resolution Panel upheld the validity of reassessment proceedings under Section 147 of the Income Tax Act. The application of Section 92 was confirmed, with adjustments made for Arm's Length Price. The Transfer Pricing Officer's computation for ALP was reduced by the DRP. Deferred receivables were considered international transactions, with interest adjustments based on short-term deposit rates. The Tribunal directed a reevaluation of interest on outstanding receivables, applying a notional interest rate. The Tribunal remanded TP adjustment and trade receivables issues for fresh adjudication, partially allowing the appeal for statistical purposes. Case-Laws Income Tax Wed, 31 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438701