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    <title>2024 (12) TMI 1056 - ITAT DELHI</title>
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    <description>A separate transfer pricing adjustment for notional interest on delayed receivables was unwarranted where the taxpayer was debt-free, no comparable interest recovery was shown, and the receivable element was already reflected in working capital adjustment; the addition was deleted. Deduction under section 35DD for the second instalment of amortised amalgamation expenditure was allowed, as the Tribunal could entertain the claim despite the absence of a revised return and the earlier assessment order supported the statutory deduction. Interest under section 234C was held to be chargeable only on returned income, not assessed income.</description>
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    <pubDate>Wed, 18 Dec 2024 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=763476</link>
      <description>A separate transfer pricing adjustment for notional interest on delayed receivables was unwarranted where the taxpayer was debt-free, no comparable interest recovery was shown, and the receivable element was already reflected in working capital adjustment; the addition was deleted. Deduction under section 35DD for the second instalment of amortised amalgamation expenditure was allowed, as the Tribunal could entertain the claim despite the absence of a revised return and the earlier assessment order supported the statutory deduction. Interest under section 234C was held to be chargeable only on returned income, not assessed income.</description>
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      <pubDate>Wed, 18 Dec 2024 00:00:00 +0530</pubDate>
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