https://www.taxtmi.com/caselaws?id=771030 The ITAT Delhi held that interest on outstanding receivables from associated enterprises constitutes an international transaction requiring transfer pricing adjustment. However, the TPO's adjustment was deleted as the assessee demonstrated superior operating profit margins (31.59%) compared to selected comparables (mean 14.30%) after working capital adjustments. Regarding Section 14A disallowance, the tribunal directed the AO to recompute using Rule 8D provisions, considering average investment values yielding exempt income. The court upheld CIT(A)'s deletion of Section 40(a)(ia) disallowance on guarantee commission payments, finding no principal-agent relationship existed between assessee and bank, thus Section 194H provisions were inapplicable. en-us Tue, 29 Apr 2025 00:00:00 +0530 Sat, 17 May 2025 11:33:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771030 The ITAT Delhi held that interest on outstanding receivables from associated enterprises constitutes an international transaction requiring transfer pricing adjustment. However, the TPO's adjustment was deleted as the assessee demonstrated superior operating profit margins (31.59%) compared to selected comparables (mean 14.30%) after working capital adjustments. Regarding Section 14A disallowance, the tribunal directed the AO to recompute using Rule 8D provisions, considering average investment values yielding exempt income. The court upheld CIT(A)'s deletion of Section 40(a)(ia) disallowance on guarantee commission payments, finding no principal-agent relationship existed between assessee and bank, thus Section 194H provisions were inapplicable. Case-Laws Income Tax Tue, 29 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771030