https://www.taxtmi.com/caselaws?id=467707 Where medical transcription and ITeS transactions were already benchmarked at arm's length under TNMM with working capital adjustment, a separate notional interest adjustment on outstanding receivables from the associated enterprise was unsustainable. The receivables arose from the same international transactions, and the working capital analysis had already captured the effect of delayed realisation. Adding interest again would duplicate the pricing impact already reflected in the arm's length margin and amount to an impermissible re-characterisation of the transaction. The transfer pricing adjustment for interest on trade receivables was therefore deleted. en-us Tue, 20 May 2025 00:00:00 +0530 Mon, 30 Mar 2026 19:50:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467707 Where medical transcription and ITeS transactions were already benchmarked at arm's length under TNMM with working capital adjustment, a separate notional interest adjustment on outstanding receivables from the associated enterprise was unsustainable. The receivables arose from the same international transactions, and the working capital analysis had already captured the effect of delayed realisation. Adding interest again would duplicate the pricing impact already reflected in the arm's length margin and amount to an impermissible re-characterisation of the transaction. The transfer pricing adjustment for interest on trade receivables was therefore deleted. Case-Laws Income Tax Tue, 20 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467707