https://www.taxtmi.com/highlights?id=74927 TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held that when TNMM is applied, the net margin already accounts for such notional interest costs. Thus, no separate adjustment for notional interest on receivables was warranted, and the tribunal directed the AO to delete the upward adjustment made for overdue receivables from AEs. - Further, Ld. AO / TPO directed to examine and consider the appropriate adjustments arising out of the working capital differences in the computation of the ALP. en-us Thu, 15 Feb 2024 07:31:11 +0530 Thu, 15 Feb 2024 07:31:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=74927 TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held that when TNMM is applied, the net margin already accounts for such notional interest costs. Thus, no separate adjustment for notional interest on receivables was warranted, and the tribunal directed the AO to delete the upward adjustment made for overdue receivables from AEs. - Further, Ld. AO / TPO directed to examine and consider the appropriate adjustments arising out of the working capital differences in the computation of the ALP. Highlights Income Tax Thu, 15 Feb 2024 07:31:11 +0530 https://www.taxtmi.com/highlights?id=74927