https://www.taxtmi.com/caselaws?id=769352 ITAT Delhi allowed the assessee's appeal regarding transfer pricing adjustments. The tribunal quashed the TPO's order for failing to follow DRP's binding directions under section 144C(10) to grant working capital adjustment, making separate interest imputation on outstanding receivables unnecessary. For foreign currency transactions with AEs, LIBOR plus 400 basis points was deemed appropriate. The tribunal held that AO cannot enhance income in final assessment order beyond what was proposed in draft assessment or considered by DRP. Interest under section 234A required verification of extended due date, while section 234C interest applies only to returned income, not assessed income. en-us Tue, 22 Apr 2025 00:00:00 +0530 Thu, 24 Apr 2025 09:13:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769352 ITAT Delhi allowed the assessee's appeal regarding transfer pricing adjustments. The tribunal quashed the TPO's order for failing to follow DRP's binding directions under section 144C(10) to grant working capital adjustment, making separate interest imputation on outstanding receivables unnecessary. For foreign currency transactions with AEs, LIBOR plus 400 basis points was deemed appropriate. The tribunal held that AO cannot enhance income in final assessment order beyond what was proposed in draft assessment or considered by DRP. Interest under section 234A required verification of extended due date, while section 234C interest applies only to returned income, not assessed income. Case-Laws Income Tax Tue, 22 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769352