https://www.taxtmi.com/caselaws?id=767140 Rectified DRP directions and the corresponding revised TPO giving-effect order must be implemented when computing income, requiring deletion of the transfer pricing adjustment for software development and IT-enabled services. Outstanding associated-enterprise receivables beyond the agreed credit period constitute a separate international transaction; interest requires independent benchmarking using a foreign-currency benchmark of LIBOR plus an arm's-length spread, limited to the relevant year. The receivables adjustment was therefore recalculated at LIBOR plus 200 basis points. A disallowance carried from an intimation into a scrutiny assessment may be examined to prevent double demand, and the section 43B issue required fresh consideration. en-us Fri, 07 Mar 2025 00:00:00 +0530 Mon, 04 May 2026 13:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767140 Rectified DRP directions and the corresponding revised TPO giving-effect order must be implemented when computing income, requiring deletion of the transfer pricing adjustment for software development and IT-enabled services. Outstanding associated-enterprise receivables beyond the agreed credit period constitute a separate international transaction; interest requires independent benchmarking using a foreign-currency benchmark of LIBOR plus an arm's-length spread, limited to the relevant year. The receivables adjustment was therefore recalculated at LIBOR plus 200 basis points. A disallowance carried from an intimation into a scrutiny assessment may be examined to prevent double demand, and the section 43B issue required fresh consideration. Case-Laws Income Tax Fri, 07 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767140