https://www.taxtmi.com/caselaws?id=775958 The ITAT Delhi allowed the assessee's appeal against TP adjustments involving notional interest on loans to AEs and outstanding receivables. The tribunal held that since no interest was charged on receivables from non-AEs, no notional interest could be attributed to AEs. Both the TPO and CIT(A) were found unjustified in sustaining such additions. Additionally, the ITAT directed the AO to apply a 1% commission rate on corporate guarantees, following precedent. The appeal was allowed for all three years under consideration. en-us Thu, 31 Jul 2025 00:00:00 +0530 Sat, 02 Aug 2025 07:24:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775958 The ITAT Delhi allowed the assessee's appeal against TP adjustments involving notional interest on loans to AEs and outstanding receivables. The tribunal held that since no interest was charged on receivables from non-AEs, no notional interest could be attributed to AEs. Both the TPO and CIT(A) were found unjustified in sustaining such additions. Additionally, the ITAT directed the AO to apply a 1% commission rate on corporate guarantees, following precedent. The appeal was allowed for all three years under consideration. Case-Laws Income Tax Thu, 31 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775958