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    <title>2023 (10) TMI 972 - ITAT DELHI</title>
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    <description>The appeal was partly allowed, primarily in favor of the assessee concerning the notional interest on overdue receivables. The Tribunal held that the adjustment for notional interest was unjustified as the assessee was a debt-free company, aligning with its previous decisions and the judgment in Pr. CIT Vs BECHTEL India Pvt. Ltd. Other issues, including TP adjustments for technical services and marketing support services, were dismissed as infructuous due to a rectification order. Issues regarding the validity of the assessment order, foreign exchange gain/loss, and penalty proceedings were not adjudicated. The stay application was deemed infructuous.</description>
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      <link>https://www.taxtmi.com/caselaws?id=444749</link>
      <description>The appeal was partly allowed, primarily in favor of the assessee concerning the notional interest on overdue receivables. The Tribunal held that the adjustment for notional interest was unjustified as the assessee was a debt-free company, aligning with its previous decisions and the judgment in Pr. CIT Vs BECHTEL India Pvt. Ltd. Other issues, including TP adjustments for technical services and marketing support services, were dismissed as infructuous due to a rectification order. Issues regarding the validity of the assessment order, foreign exchange gain/loss, and penalty proceedings were not adjudicated. The stay application was deemed infructuous.</description>
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