https://www.taxtmi.com/caselaws?id=465416 Following prior HC rulings, the Court held that interest on delayed realization of outstanding receivables does not constitute an "international transaction" amenable to TP adjustment; the TP addition on this count was unsustainable. On disallowance under s. 40(a)(ia) concerning secondees' remuneration, it affirmed the Tribunal's finding that the secondees functioned as the taxpayer's employees, attracting TDS under s. 192 and excluding the application of s. 195; the disallowance was therefore deleted. On the addition for non-charging of mark-up on support service charges to a resident Indian affiliate, it held that absent statutory mandate and revenue loss, commercial terms between resident parties could not be rewritten; the addition was deleted. The Court admitted the appeal only on the question concerning year-end accruals/excess provisioning and lack of supporting evidence. en-us Mon, 16 Dec 2024 00:00:00 +0530 Fri, 19 Dec 2025 14:25:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465416 Following prior HC rulings, the Court held that interest on delayed realization of outstanding receivables does not constitute an "international transaction" amenable to TP adjustment; the TP addition on this count was unsustainable. On disallowance under s. 40(a)(ia) concerning secondees' remuneration, it affirmed the Tribunal's finding that the secondees functioned as the taxpayer's employees, attracting TDS under s. 192 and excluding the application of s. 195; the disallowance was therefore deleted. On the addition for non-charging of mark-up on support service charges to a resident Indian affiliate, it held that absent statutory mandate and revenue loss, commercial terms between resident parties could not be rewritten; the addition was deleted. The Court admitted the appeal only on the question concerning year-end accruals/excess provisioning and lack of supporting evidence. Case-Laws Income Tax Mon, 16 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465416