https://www.taxtmi.com/caselaws?id=445305 ITAT Ahmedabad held that an authentic internal CUP was preferable for benchmarking interest on advances to associated enterprises, so the transfer pricing adjustment was deleted. It further held that where sales were benchmarked under TNMM with working capital adjustment, separate notional interest on overdue receivables from the same transactions could not be added. Purchases from a partnership firm could not be treated as a specified domestic transaction after omission of the relevant clause in section 92BA, and the related adjustment was deleted. The Tribunal also held that section 35(2AB) deduction could not be restricted merely to Form 3CL, deleted interest and section 14A disallowances where own funds were sufficient, and held that foreign commission paid for services rendered outside India was not liable to disallowance under section 40(a)(ia). en-us Tue, 31 Oct 2023 00:00:00 +0530 Fri, 03 Nov 2023 15:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445305 ITAT Ahmedabad held that an authentic internal CUP was preferable for benchmarking interest on advances to associated enterprises, so the transfer pricing adjustment was deleted. It further held that where sales were benchmarked under TNMM with working capital adjustment, separate notional interest on overdue receivables from the same transactions could not be added. Purchases from a partnership firm could not be treated as a specified domestic transaction after omission of the relevant clause in section 92BA, and the related adjustment was deleted. The Tribunal also held that section 35(2AB) deduction could not be restricted merely to Form 3CL, deleted interest and section 14A disallowances where own funds were sufficient, and held that foreign commission paid for services rendered outside India was not liable to disallowance under section 40(a)(ia). Case-Laws Income Tax Tue, 31 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445305