https://www.taxtmi.com/caselaws?id=771314 The ITAT Ahmedabad ruled in favor of the assessee regarding upward adjustment for notional interest on outstanding receivables from associated enterprises. The tribunal held that separate benchmarking of receivables was unnecessary when underlying sale transactions were already accepted as arm's length under TNMM. The court found that working capital adjustments already neutralized the impact of extended credit periods, making additional adjustments duplicative. Since no discriminatory credit terms existed between AEs and non-AEs, and TNMM evaluates net profitability holistically, the adjustment was deleted entirely. Consequently, penalty proceedings under section 270A were also cancelled. en-us Wed, 21 May 2025 00:00:00 +0530 Fri, 23 May 2025 08:46:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771314 The ITAT Ahmedabad ruled in favor of the assessee regarding upward adjustment for notional interest on outstanding receivables from associated enterprises. The tribunal held that separate benchmarking of receivables was unnecessary when underlying sale transactions were already accepted as arm's length under TNMM. The court found that working capital adjustments already neutralized the impact of extended credit periods, making additional adjustments duplicative. Since no discriminatory credit terms existed between AEs and non-AEs, and TNMM evaluates net profitability holistically, the adjustment was deleted entirely. Consequently, penalty proceedings under section 270A were also cancelled. Case-Laws Income Tax Wed, 21 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771314