https://www.taxtmi.com/caselaws?id=467548 Delayed receivables from associated enterprises are treated as a separately benchmarkable international transaction under transfer pricing rules, and an invoice-wise adjustment confined to the credit period can be applied where the assessee fails to produce reliable working-capital substantiation. Corporate guarantee commission is also treated as an international transaction because the guarantee confers measurable benefit and improves the associate's creditworthiness, supporting an arm's length charge. Credit for prepaid taxes and rectification relating to creditors write-back require verification at assessment level, while a penalty ground is premature where penalty has only been initiated and interest follows the sustained additions. en-us Thu, 28 Aug 2025 00:00:00 +0530 Mon, 23 Mar 2026 20:37:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467548 Delayed receivables from associated enterprises are treated as a separately benchmarkable international transaction under transfer pricing rules, and an invoice-wise adjustment confined to the credit period can be applied where the assessee fails to produce reliable working-capital substantiation. Corporate guarantee commission is also treated as an international transaction because the guarantee confers measurable benefit and improves the associate's creditworthiness, supporting an arm's length charge. Credit for prepaid taxes and rectification relating to creditors write-back require verification at assessment level, while a penalty ground is premature where penalty has only been initiated and interest follows the sustained additions. Case-Laws Income Tax Thu, 28 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467548