https://www.taxtmi.com/caselaws?id=464272 ITAT remitted two issues. First, it directed the TPO to treat interest on outstanding receivables/payables with the AE as an international transaction under s.92B, applying FIFO so advances are first adjusted and interest computed only on true outstanding invoices before determining ALP. Second, it remitted the s.40(a)(ia) disallowance for reimbursement of salary (invoking s.194J) to the AO to verify whether the recipient declared and paid tax on the receipt; if tax was paid by the recipient, no disallowance is to be made. en-us Thu, 05 Mar 2020 00:00:00 +0530 Mon, 13 Oct 2025 18:00:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464272 ITAT remitted two issues. First, it directed the TPO to treat interest on outstanding receivables/payables with the AE as an international transaction under s.92B, applying FIFO so advances are first adjusted and interest computed only on true outstanding invoices before determining ALP. Second, it remitted the s.40(a)(ia) disallowance for reimbursement of salary (invoking s.194J) to the AO to verify whether the recipient declared and paid tax on the receipt; if tax was paid by the recipient, no disallowance is to be made. Case-Laws Income Tax Thu, 05 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464272